What is comparability analysis for transfer pricing in Malaysia?

KnowledgeWhat is comparability analysis for transfer pricing in Malaysia?

What is the comparability analysis for transfer pricing in Malaysia?

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.   

The application of the arm's length principle is based on a comparison of conditions in a controlled transaction (associated entities) with those in an uncontrolled transaction (independent entities) under comparable circumstances. This is known as the comparability analysis.

A comparability analysis requires the selection of reliable comparables and it could be either internal or external comparables:

Internal comparables

External comparables

Transactions carried out by the tested party and independent entities in comparable circumstances

Transactions between independent entities which is comparable to the tested party


What are the Five Comparability Factors?

An uncontrolled transaction is deemed comparable if the following five comparability factors are sufficiently similar with the controlled transaction:

Questions?

Transfer Pricing Solutions Malaysia can assist with the preparation of TP documentation locally and regionally, Master File and Local File to comply with the OECD and also local legislation.

CONTACT US CONTACT US

Related Blogs

15 Aug

Made Errors in Transfer Pricing? IRAS’ VDP Can Help

Inland Revenue Authority of Singapore (“IRAS”) offers a Voluntary Disclosure Programme (“VDP”) help taxpayers rectify these errors and minimize potential penalties.


READ MORE READ MORE
30 May

Navigating the Maze: Strategies for Resolving Transfer Pricing Disputes

The world of transfer pricing can be a complex and sometimes treacherous one, especially when disputes arise.


READ MORE READ MORE
30 Apr

2024 Updates on Global Minimum Tax

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.


READ MORE READ MORE