On 1 June 2023, the Malaysian Institute of Accountants (MIA) held their Transfer Pricing Conference at the Kuala Lumpur Convention Centre, a gathering of the highest regarded transfer pricing and tax professionals in Malaysia and Asia to keep delegates up to date on the latest developments, in particular how the 15% Global Minimum Tax will affect TP within the global and Malaysian context.
The Conference featured leaders from the Lembaga Hasil Dalam Negeri and a panel of expert speakers offering informative dialogues to provide crucial insights into transfer pricing best practices, such as technology adoption and process automation to ensure regulatory compliance and optimise transfer pricing models for a globally realigned supply chain.
Transfer Pricing Solutions Malaysia Directors, Hong Chuan Tan and Adriana Calderon were delighted to have been invited to present on the topic of Global Minimum Tax to a highly targeted and engaged audience including tax practitioners, CFOs and accountants.
Participants were exposed to effective techniques for improving the processes of managing cross-border transactions and keeping TP
documentation, as well as how to properly consider the advantages and disadvantages of employing the profit split methodology. The
Conference also focussed on how to effectively mitigate and manage TP risks while adhering to tax legislation in both the global and
Malaysian contexts.
In response to the introduction of Pillar Two (a global minimum effective corporate tax rate of 15%), Multinational Corporations (MNCs)
need to transform their transfer pricing (TP) model that will help ensure true allocation of taxable income across jurisdictions. The role
of transfer pricing is to help create a fiscally optimal supply chain model and defend the remuneration of MNC companies in line with
their value in a realigned supply chain.
Adriana and Hong Chuan's session discussed how the 15% Global Minimum Tax will have a significant impact on Transfer Pricing as the
heart of the analysis when it comes to important business functions.
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Are you prepared for new global minimum tax measures? Do you know the key impact on your transfer pricing framework?
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.
