TRANSFER PRICING

Transfer Pricing Dispute Mitigation

Proactive strategies to prevent TP disputes

Prevent disputes through APAs, MAPs and proactive engagement with tax authorities


We help businesses minimise uncertainty and prevent disputes through pre-emptive strategies that provide clarity and certainty over their transfer pricing arrangements, as well as minimising double taxation risks.

Our team supports you in engaging with tax authorities to achieve practical, forward-looking solutions, including:

  • Advance Pricing Agreements (APA): Enables taxpayers engaged in cross-border controlled transactions to obtain upfront certainty on transfer pricing arrangements, subject to meeting prescribed conditions.     
    1. Pre-filing meeting
    2. Submission of formal application
    3. Reviewing and negotiating the application
    4. Implementation of the APA
    5. APA monitoring and compliance review
  • Mutual Agreement Procedures (MAP): Provides a formal process for resolving treaty-related disputes through the Malaysian Competent Authority, ensuring relief from double taxation in accordance with applicable tax treaties. 

How we can help


  • Application for APA & MAP 

Your smarter choice in managing transfer pricing

We have deep transfer pricing knowledge and experience spanning decades and across industries. We use a collaborative and custom approach to develop solutions tailored for your unique situation.

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We are here to help

Working together we can help you successfully adapt and overcome the challenges you may face, both today and in the future.
Foo Meng Huei
Meng Huei Foo
Head of TaxKuala Lumpur
Song Sylvia
Sylvia Song
Partner, Transfer PricingKuala Lumpur
Wong Chun Kit
Chun Kit Wong
Partner, Transfer PricingKuala Lumpur