Malaysia’s New Transfer Pricing Guidelines on Intra-Group Loans
Learning Centre • Videos & Webinars • Malaysia’s New Transfer Pricing Guidelines on Intra-Group Loans
Learning Centre • Videos & Webinars • Malaysia’s New Transfer Pricing Guidelines on Intra-Group Loans
On 30 July 2026, the Inland Revenue Board of Malaysia (IRBM) released the Malaysia Transfer Pricing Guidelines on Controlled Financial Transactions: Intra-Group Loans. The guidance goes well beyond interest rate benchmarking: taxpayers must now first show that a purported loan is genuinely debt, and then support its pricing with robust credit and comparability analysis.
Intra-group financing is no longer a routine interest rate exercise. With the IRBM’s stronger focus on substance, debt-versus-equity characterisation, creditworthiness and documentation, both the structure and the pricing of intra-group loans must now withstand detailed scrutiny. Groups that review their arrangements early will be best placed to minimise audit risk and maintain tax certainty.
Join Transfer Pricing Solutions for a practical, insight-driven webinar that walks through what the new guidelines require, where the audit risks lie, and what Malaysian taxpayers and their parent groups should be doing now to review their intra-group financing.
WHAT WE COVERED
We’d love to chat further. Please get in touch to discuss how Transfer Pricing Solutions Asia can assist with your intra-group financing arrangements.