Transfer Pricing Dispute Mitigation

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.