As global tax reform reshapes the way multinationals manage cross-border transactions, Operational Transfer Pricing (OTP) is rapidly becoming a business-critical priority, especially in the Asia-Pacific (APAC) region.
As global trade becomes more complex, companies are re-examining their supply chains - and transfer pricing is at the heart of that conversation.
In multinational enterprises, it is common for parent companies or group service companies to provide intra group services to related parties. These services are outsourced to the group service provider for business convenience and efficiency reasons.
Malaysian Taxpayers who use the 5% markup concession are still required to prepare documentation to address other fundamentals aspects of a service charge.
Transfer pricing refers to the pricing of transactions between related parties, such as sales of goods, provision of services, or financial arrangements. To ensure these transactions are conducted at arm’s length, the Inland Revenue Board of Malaysia (IRBM) requires taxpayers to prepare Transfer Pricing Documentation (TPD).
From 1 January 2025 to 31 December 2034, companies operating in qualifying sectors can apply to the Malaysian Investment Development Authority (MIDA) for the various tax incentive schemes under the JS-SEZ Tax Incentives Package.
The Johor-Special Economic Zone (JS-SEZ) is a strategic initiative between Singapore and Malaysia aimed at fostering cross-border economic growth.
Since 2017, the Inland Revenue Authority of Singapore (IRAS) has provided indicative margins to help businesses determine an arm’s length interest rate for related party loans. In this article we example the margins.
As of January 1, 2025, new amendments to Singapore's Transfer Pricing (TP) regulations will impact how intra-group loans are handled—specifically for domestic financing arrangements. These updates introduce significant changes that businesses must consider to ensure compliance and avoid potential tax penalties. Here’s what you need to know.
The long-awaited Malaysia Transfer Pricing Guidelines 2024 are finally here, and they bring significant updates aimed at enhancing clarity, compliance, and alignment with global practices. Here’s a breakdown of the key changes every business should know.
This article will provide an overview of what global minimum tax is, why it's important, and how it impacts multinational corporations and the global economy.
This article will explore the history of global minimum tax policies, from their origins to the latest developments, including the recent OECD/G20 agreement.
This article will discuss how technology can help multinational corporations streamline their global minimum tax compliance.
This article will discuss how global minimum tax policies affect multinational corporations, including changes to their tax planning strategies and compliance requirements.
This article will provide practical advice for multinational corporations on how to navigate the complexities of global minimum tax compliance.
This article will speculate on the future of international taxation in light of global minimum tax policies, including potential trends and challenges that may arise.
This article will examine the challenges and opportunities that global minimum tax policies present for developing countries, including their potential impact on tax revenue and economic development.
Are your financing terms optimized and aligned with the economic reality of your transactions?
Inland Revenue Authority of Singapore (“IRAS”) offers a Voluntary Disclosure Programme (“VDP”) help taxpayers rectify these errors and minimize potential penalties.
Not all services are created equal. Identifying low-value and high-value services within your intra-group transactions is a fundamental distinction.
The world of transfer pricing can be a complex and sometimes treacherous one, especially when disputes arise.
Global Minimum Tax (GMT) is one of the largest tax reformations as part of the initiative under Pillar 2 of the Base Erosion Profit-Shifting (BEPS) 2.0 project.
On 19 February 2024, OECD published the final report on Pillar One -Amount B, is designed to simplify and streamline the application of the arm’s length principle.
With increasing scrutiny, transfer pricing audits are becoming more common. Failure to comply with documentation requirements can lead to significant penalties.
The IRBM has recently issued a Frequently Asked Questions to address the questions taxpayers and tax professionals regarding the Transfer Pricing Surcharge.
The recently announced Singapore Budget 2024 tabled by Deputy Prime Minister and Finance Minister, Mr. Lawrence Wong on 16 February 2024.
Malaysia taxpayers will be required to include the date on which their contemporaneous TP documentation is completed from YA 2023.
Be prepared for potential transfer pricing audits by tax authorities. Ensure that your transfer pricing documentation is readily available, organized, and easily accessible.
There is an increasing focus on transfer pricing documentation for intragroup loans in Malaysia. Tax authorities expect comprehensive documentation that demonstrates the arm's length.
In Singapore Taxpayers are required to review and update your transfer pricing documentation annually to ensure its accuracy and relevance.
The submission of corporate tax returns dateline in Singapore is around the corner with most companies having to submit their tax return by 30 November 2023.
TNMM is a widely used transfer pricing method by tax authorities and multinational companies because it is considered to provide a more accurate outlook of the profitability.
PSM is generally used when there is significant value contributed by each party to the transaction and should be resorted to when it has
been difficult to determine an arm's length.
Malaysia published its new transfer pricing (TP) rules in May and these are certainly creating a buzz on the ground, especially with many companies having related party transactions between both sides of the Causeway.
Intra-group service is one of the most common international related party transactions entered by Malaysian Taxpayers.
In this article we will explore the Resale Price Method (“RPM”) and see how this differs to the other traditional methods.
The CP method forms part of the traditional transfer pricing approach. Cost Plus means adding a markup to the actual cost incurred by a Company in producing or acquiring a product or service.
The CUP method is a well-established traditional transfer pricing approach. This method is used to determine the arm's length price for transactions between related parties, also known as controlled transactions.
Transfer Pricing Solutions Malaysia were delighted to present on the topic of Global Minimum Tax and Impact on transfer pricing at the Malaysian Institute of Accountants conference in June 2023.
In Malaysia, the transfer pricing requirements are governed by the Income Tax Act 1967 (“ITA”) and the Malaysian Transfer Pricing Guidelines (“TP Guidelines”).
FAQs on Transfer Pricing Requirements in Malaysia.
When inflation is high, the cost of goods and services increases, so the prices of those goods and services must also increase to reflect the higher costs.
Multinational enterprises (MNEs) must not only navigate global transfer pricing regulations but also be aware of the economic climate to maintain tax efficiency and adhere to the arm's length standard.
The transfer pricing landscape in Asia is expected to undergo significant changes in the coming years.
Global minimum tax is a tax policy proposal that would require large multinational corporations to pay a minimum tax rate on their profits, regardless of where they are located.
In this first article we will discuss the differences between transactional and traditional methods and considerations to be taken into account.
Whether you need to prepare a benchmarking study when entering into a related party transaction depends on the country's transfer pricing regulations and the specifics of the transaction.
If you are reading this article the chances are that you enjoy discussing about technical aspects of transfer pricing as much as we do. Any transfer pricing aficionado knows that changes to the OECD Transfer Pricing Guidelines are a reason for excitement in the tax and transfer pricing world.
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