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#TRANSFER PRICING TAX LICENSE#
#TRANSFER PRICING TAX PROFESSIONAL#

97 of 2023 announcing the Requirements for Maintaining Transfer Pricing Documentation for the purposes of complying with the Federal Decree-Law No.

#TRANSFER PRICING TAX PROFESSIONAL#

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#TRANSFER PRICING TAX LICENSE#

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The minimum transfer pricing documentation template (for taxpayers with gross income not exceeding RM25 million or related party transactions not exceeding RM15 million) was updated to remove the need to characterize the business activity and the disclosure requirement for dividend, and explanatory notes were attached to help taxpayers complete the template.The provision allowing taxpayers to request for offsetting adjustments was removed.Taxpayers must include in their contemporaneous transfer pricing documentation details of the IP used, the group’s strategy for the development, ownership and exploitation of the IP, locations of the research and development facilities and more. The rules make it clear that an owner of intangible property (IP) that does not perform the functions nor control the functions or risks related to the development, enhancement, maintenance, protection and exploitation (DEMPE) of the IP is not entitled to any income attributable to the IP.

The list of information that needs to be included in the contemporaneous transfer pricing documentation was expanded to include extensive information on the multinational enterprise group that is typically part of the group’s Master file.

The contemporaneous transfer pricing documentation must be submitted within 14 days upon request by the MIRB.

To be contemporaneous, transfer pricing documentation must be completed prior to the due date for furnishing a tax return for that YA.

Outside the arm’s length range, the arm’s length price shall be taken to be the median.

There are comparability defects which cannot be quantified, identified, or adjusted.

The comparable data is the kind which has a lesser degree of comparability, or.

However, the MIRB may still adjust the price of the controlled transaction to the median or any other point above median (within the arm’s length range) when:

Within the arm’s length range, such price may be regarded to be the arm’s length price.

If the price of the controlled transaction is:

The arm’s length range is now defined as a range of figures or a single figure falling between the value of 37.5 percentile to 62.5 percentile of the benchmarking data set, when acceptable by the MIRB.

The new rules will significantly enhance and strengthen the position of the Malaysia Inland Revenue Board (MIRB) on transfer pricing enforcement, and include the following features: The Income Tax (Transfer Pricing) Rules 2023 were published in the official gazette on and are effective for year of assessment (YA) 2023 and subsequent YAs.