28 Nov
IRBM’s Transfer Pricing Audit Focus – What Companies Need to Know
IRB’s Latest Audit Focus What Companies Need to Know In recent years, the Inland Revenue Board of Malaysia (IRBM) has escalated its scrutiny over transfer pricing, signalling a stricter enforcement environment for taxpayers engaged in related-party or controlled transactions. In December 2024, IRBM released Malaysia Transfer Pricing Guidelines 2024 (MTPG 2024), which revoked its […]
13 Nov
Understanding Controlled Transactions – Insights from Malaysia’s Transfer Pricing Regulations
Understanding Controlled Transactions – Insights from Malaysia’s Transfer Pricing Regulations Are all business transactions created equal? It is questionable, as the transfer pricing environment, where transactions between two related entities within a same group are often conducted differently as compared with those between independent parties. The element of “control” plays a dominant role in every […]
29 Oct
What is Functional Analysis? Why does it matter?
What is Functional Analysis? Why does it matter? Under Malaysia’s transfer pricing regulations, functional analysis is a central component of transfer pricing compliance stipulated in the Transfer Pricing Guidelines 2024 (MTPG 2024) which is largely aligned with the OECD’s transfer pricing guidance. During an IRBM (Inland Revenue Board of Malaysia) audit, companies must demonstrate […]