Malaysia’s New Transfer Pricing Guidelines on Intra-Group Loans
Events • Malaysia’s New Transfer Pricing Guidelines on Intra-Group Loans
Events • Malaysia’s New Transfer Pricing Guidelines on Intra-Group Loans
WEBINAR
Malaysia’s New Transfer Pricing Guidelines on Intra-Group Loans |
Are your intra-group loans ready for the IRBM’s new transfer pricing guidelines?
On 30 July 2026, the Inland Revenue Board of Malaysia (IRBM) released the Malaysia Transfer Pricing Guidelines on Controlled Financial
Transactions: Intra-Group Loans. The guidance goes well beyond interest rate benchmarking. Taxpayers must now first show that a purported
loan is genuinely debt, and then support its pricing with robust credit and comparability analysis. Join Transfer Pricing Solutions for a
practical, insight driven webinar that walks through what the new guidelines require, where the audit risks lie, and what Malaysian
taxpayers and their parent groups should be doing now to review their intra-group financing. Intra-group financing is no longer a
routine interest rate exercise. With the IRBM’s stronger focus on substance, debt versus equity characterisation, creditworthiness and
documentation, both the structure and the pricing of intra-group loans must now withstand detailed scrutiny. Groups that review their
arrangements early will be best placed to minimise audit risk and maintain tax certainty.
IN THIS WEBINAR PARTICIPANTS WILL:
THE DETAILS
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DATE |
29 October 2026 |
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TIME |
2:00 - 3.00pm (Singapore time) |
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COST |
Free |
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ADRIANA CALDERON Ms Adriana Calderon Director, Asia and Malaysia - Transfer Pricing Solutions Asia Accredited Tax Advisor (Income Tax) Adriana is the co-founder of Transfer Pricing Solutions Asia. She has extensive international experience with Big Four and mid-tier firms advising multinational companies in the areas of corporate and international taxation across South America, the US, Australia and the Asia Pacific Region. As a Transfer Pricing practitioner, Adriana has advised companies in the Asia Pacific Region across various industries and in a wide range of projects associated with planning, compliance and dispute resolutions with tax authorities. She has also participated in specialised projects involving pricing of financial transactions, business restructures and negotiation of APAs. Most recently, she has participated in transfer pricing planning projects to implement BEPS’s Action Plan and country-by-country reporting. Adriana also enjoys teaching and is a regular speaker and facilitator of Transfer Pricing seminars and workshops.
She is a transfer pricing trainer for the Institute of Singapore Chartered Accountants and Singapore Institute of Accredited Tax
Professionals. Adriana has also facilitated training sessions for CFOs, tax teams of large companies and consultancies, and tax
executives at the Australian Taxation Office. In addition, Adriana is also SCTP’s representative for the TP Roundtables organised by
the tax authority.
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Singapore's latest transfer pricing guidance brings welcome clarity on share-based compensation in intercompany service fees. Discover what has changed, the opportunities available for earlier years, and why businesses should review their arrangements before key deadlines.
Transfer pricing season is here. From new guidance on related party transactions to enhanced focus on loans and documentation, learn the key updates, common pitfalls, and practical questions every Singapore business should be asking before year-end.
On 30 July 2026, the Inland Revenue Board of Malaysia (IRBM) released its new Malaysia Transfer Pricing Guidelines on Controlled Financial Transactions: Intra-Group Loans (MFTIL). The guidance provides a comprehensive framework for assessing, pricing and documenting intra-group loans under Malaysia’s transfer pricing regime.
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