Malaysia’s New 5% Mark-Up for Intra-Group Services: A True Compliance Relief or Just a Mirage?
Knowledge • Malaysia’s New 5% Mark-Up for Intra-Group Services: A True Compliance Relief or Just a Mirage?
Knowledge • Malaysia’s New 5% Mark-Up for Intra-Group Services: A True Compliance Relief or Just a Mirage?
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. In Malaysia, the
Inland Revenue Board of Malaysia (“IRB”) introduced the Transfer Pricing Guidelines released in December 2024 (“TPG24”), which incorporates
the Low Value-Adding Services (“LVAS”) concession. A relief for service providers that provide routine, low value adding services to their
related parties.
Need a Malaysian transfer pricing expert? Contact us to discuss your transfer pricing compliance requirements.
Malaysia’s transfer pricing framework continues to evolve, with the Inland Revenue Board of Malaysia applying increasing scrutiny to how multinational groups price, document and defend related‑party transactions. For businesses operating in Malaysia, transfer pricing has become a core tax risk area rather than a routine compliance exercise.
As tariff wars intensify, government deficits balloon, and supply chains fragment, the OECD’s 15% global minimum tax has shifted from a technical compliance issue to a strategic imperative reshaping how and where multinational enterprises compete.