Transfer Pricing Documentation

Importance of Having

Transfer Pricing Documentation (TPD)

Statutory Compliance in Malaysia

TPD is required by applicable laws, regulations, and guidelines governed by Malaysia regulatory authorities for businesses having controlled transactions. Non-compliance will attract heavy penalties, tax adjustment to be imposed by Inland Revenue Board, and/or imprisonment.

Contemporaneous Documents

TPD is required to be contemporaneous and to be prepared to justify that pricing is at arm’s length according to the requirements of the Rules and Guidelines.

Tax Planning

TPD provides insights into your transfer pricing policies using the appropriate transfer pricing methods to optimize your profit through proper tax management strategies.

Build Your Audit Defense

TPD can serve as a strategic compliance lens to your business operation to ensure records and documents matches the way the business is conducted. Having a defensible strategy in transfer pricing policies is helpful to achieve a favorable resolution in an Audit Investigation by Inland Revenue Board. This is fundamental to have all your supporting evidence when your transfer pricing policies are challenged in an audit investigation.

What If I Already Have A TPD?

We provide ancillary services to support your business:

Yearly Update

TPD must be updated in the 2nd and 3rd year after the initial TPD was written subject to no material change to your business operation. We provide updates and evaluations to your existing comparability data to support your TPD.

Technical Benchmarking Analysis

A new benchmarking evaluation and analysis are required every three years. We provide this report for easy usage in your TPD.

Intercompany Agreements

Intercompany agreements are required to document the parties, terms, allocation of risk, and other related matters of your controlled transactions. We take extra care to understand the pertinent factors that influenced your pricing policy incorporating the benchmarking analysis in drafting your intercompany agreements.