Transfer pricing (TP) is the setting of transfer prices for transactions relating to sales and purchases of goods, services, intangibles and financing provided between associated persons within a Group.
All related party transactions are required to be conducted at arm’s length prices, i.e. the prices set for transactions between associated persons should approximate the prices set between independent parties undertaking transactions under similar or comparable terms and conditions. The key challenge is firstly to set up the arm’s length transfer prices and to defend them against any challenges by the tax authorities. Internally within a group, the other challenge is managing the transfer pricing risks associated with tax planning and tax compliance.
Transfer pricing is complex and getting it wrong can be costly. With constantly changing tax legislation, the need for specialist tax advice has never been greater. Given the current situation where the tax authorities have provided the basic framework to implement transfer pricing in the country, taxpayers have no valid grounds for ignoring their responsibilities to comply with the transfer pricing regime.
Our transfer pricing unit offers a full range of transfer pricing services. This team of experienced tax and transfer pricing specialists will ensure that you receive the highest level of support in managing your transfer pricing affairs. We are ranked a Top Tier firm in Malaysia for our Transfer Pricing services by the World TP Guide, reflecting our proven expertise and commitment to excellence. In addition, our network of member firms in 140+ countries across the globe and strategic competencies place us in the position to provide an all-rounded approach for your organisation’s transfer pricing needs.
Malaysia Transfer Pricing 2024 Update
The Malaysia Transfer Pricing Guidelines 2024 mandates:
All taxpayers must prove arm’s length compliance. Read Full Guidelines
Our Services:
The year 2025 marks a new dawn in the Malaysian tax landscape with the implementation of Global Minimum Tax ("GMT") regime for large multinationals, aligned with international tax development towards a fairer corporate taxation system. Multinationals with annual revenues of at least EUR 750 million, in at least 2 of the 4 consecutive financial years immediately preceding the tested financial year, shall be subject to either the Multinational Top-up Tax (MTT) or Domestic Top-up Tax (DTT), as stipulated in Part XI of the Malaysian Income Tax Act 1967. The GMT legislation will take effect from 1 January 2025.
Constituent Entities (CE) of an multinational enterprise (MNE) group shall prepare and submit to the Inland Revenue Board of Malaysia (IRBM) a GloBE Information Return and a Top-up Tax Return for each Financial Year electronically not later than 15 months from the last day of the Reporting Financial Year.
We assisted a multinational corporation headquartered in Malaysia to prepare a three-tier documentation that complies with BEPs requirements, Country-by-Country Reporting Rules and Malaysian Transfer Pricing provisions.
The documentation comprises a Country-by-Country Report, Master File and Local File as stipulated under the guidelines of the Malaysian tax authorities.
We assisted a company to successfully defend its Transfer Pricing dispute against the Malaysian tax authorities.
The company was alleged to have not complied with the Malaysian Transfer Pricing provisions with regard to interest-free intra-group balances. We defended the company and secured a very favorable outcome.
We assisted a manufacturing company that was headquartered outside Malaysia to prepare Transfer Pricing documentation for their operations in Cambodia.
The documentation arose as a result of Transfer Pricing rules introduced recently by the Cambodian Government that required all companies to prepare relevant transfer pricing documentation to substantiate their controlled transactions. We worked with our Cambodia Office to successfully prepare the documentation that complied with the Cambodia Transfer Pricing Rules.
Companies operating in the APAC region need to be aware of transfer pricing regulations and ensure that their transfer pricing practices comply with local laws to avoid potential penalties and reputational damage.
Accounting advisory
Complexity is our specialty. Work with teams that understand all facets of your accounting needs – from complex reporting requirements to strategic transactions to finance transformation.
ESG services
Sustainability is our focus. Partner with experts offering tailored ESG solutions, from strategy to compliance and reporting to helping your business meet its goals and drive value.
Family office
Preserve and grow family wealth. Our tailored solutions ensure smooth succession, tax efficiency and alignment with your values.
Accounting advisory
Complexity is our specialty. Work with teams that understand all facets of your accounting needs – from complex reporting requirements to strategic transactions to finance transformation.
ESG services
Sustainability is our focus. Partner with experts offering tailored ESG solutions, from strategy to compliance and reporting to helping your business meet its goals and drive value.
Family office
Preserve and grow family wealth. Our tailored solutions ensure smooth succession, tax efficiency and alignment with your values.
