Seminar: Transfer Pricing Guidelines 2024 – Enhanced Clarity and Simplifying Documentation

INTRODUCTION

In December 2024, the Inland Revenue Board of Malaysia (“IRBM”) has published the Malaysia Transfer Pricing Guidelines 2024 (“MTPG 2024”) and Transfer Pricing Tax Audit Framework (“TPAF”). These follow the release of the Income Tax (Transfer Pricing) Rules 2023 [P.U.(A) 165/2023] (“TP Rules”) and the amendments to the Income Tax Act 1967 (the “Act”) that introduced section 113B and subsections 140A (3A), (3B), (3C), and (3D).

COURSE OUTLINE

In this seminar, the speakers will elaborate on the following, in addition to sharing their experience from tax audits.

• Key changes introduced through MTPG 2024

– Thresholds for full TPD versus Minimum TPD
– Exemption from documentation under specific scenarios
– Application of the penalty scale under S.113B of the ITA

• Recharging costs without mark-up: the new pass-through cost guidance.

• Intragroup management services and the new simplified approach – how taxpayers can benefit.

• Interest free loans – application of the new guidance for preparing supporting documentation.

• Relevance of intercompany agreements in transfer pricing, and allied considerations.

If you are interested to join the Members’ Dialogue – An Exclusive Event for CTIM Members ONLY please click on the link below for the registration purposes.

https://www.ctim.org.my/event/members-dialogue-an-exclusive-event-for-ctim-members-only-perak/