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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With the new transfer pricing changes in Malaysia and the new transfer pricing documentation standard, a benchmarking analysis that is reliable and defendable, is key when preparing transfer pricing documentation. For this reason, we have compiled key tips that in our experience will help you getting a benchmarking analysis right.
The Inland Revenue Board of Malaysia (“IRBM”) adopts the arm’s length principle as a basis to determine the transfer price of a transaction between associated entities. Arm’s length price is the price which would have been determined if such transactions were entered between independent entities under the same or similar circumstances.