CPD EVENTS
INTRODUCTION
Recently our Ministry of Finance issued the Income Tax (Transfer Pricing) Rules 2023 (“Malaysian TP Rules 2023”). This replaces the Income Tax (Transfer Pricing) Rules 2012 which was issued in May 2012. The latest Malaysian TP Rules 2023 is effective from year of assessment 2023.
Rule 11 emphasis on intangible property from TP perspective; Rule 10 discuss about cost contribution arrangement. In addition, it is a new requirement to disclose cost contribution arrangement information and document in the TP documentation.
COURSE OUTLINE
-
Identifying intangibles and ownership;
-
Analysing transactions involving Development, Enhancement, Maintenance, Protection and Exploitation (DEMPE) for intangible property;
-
Application of TP method to determine arm’s length price;
-
Cost contribution arrangement v intra group services; and
-
Disclosure of cost contribution arrangement in the TP documentation