Treasure Advisory Sdn. Bhd. 201801013345 (1275361-P)
D-1-09, Plaza Arkadia, No.3, Jalan Intisari Perdana,
Desa Parkcity, 52200 Kuala Lumpur, Malaysia.
Transfer Pricing Policy
The governing standard for transfer pricing is the arm’s length principle which is provided in Income Tax Act 1967, Income Tax (Transfer Pricing) Rules 2023, Malaysia Transfer Guidelines 2012, OECD Transfer Pricing Guidelines 2022 and UN Manual on Transfer Pricing 2021. Documenting transfer pricing policy is crucial. It serves as an important set of supporting documents
to substantiate your pricing position when objecting to an unfavourable outcome from the Inland Revenue Board Malaysia (IRBM) tax audit. In Malaysia, companies must adhere to strict regulations, which require maintaining a comprehensive transfer pricing policy and documentation. Without any form of supporting documents, the task to defend your transfer price in any tax audits and disputes will be an uphill task.
what is transfer pricing meaning?
Determine which company is selling goods or providing services to which entity in the Group who have purchased the goods or is the recipient of the services.
It is of utmost importance to accurately delineate the controlled transactions. It provides the basis to determine the arm’s length price.s.
Functional characteristic of entities would be performed to analyse the functions performed, assets employed and risks undertaken by each entity in the controlled transactions.
The pricing setting methodology will be documented. Factors such as shared cost, profit level indicator, allocation keys and others may be chosen to elaborate the pricing setting processes.
Comparability studies to be conducted and the arm’s length price to be determined.
Treasure Advisory Sdn. Bhd. 201801013345 (1275361-P)
D-1-09, Plaza Arkadia, No.3, Jalan Intisari Perdana,
Desa Parkcity, 52200 Kuala Lumpur, Malaysia.