22/01/2025 10:00
22/01/2025 12:00
The Malaysian Transfer Pricing Guidelines 2024 (MTPG 2024) represent a landmark update in the nation’s transfer pricing framework, reflecting the Inland Revenue Board of Malaysia’s (IRBM) commitment to aligning local practices with international standards, particularly the OECD Transfer Pricing Guidelines. Released on 24 December 2024, these new guidelines replace the 2012 version, introducing key revisions such as updated thresholds for documentation, a narrower Arm’s Length Range (ALR) and specific provisions for intra-group services, financial transactions and business restructuring. With these changes, the IRBM aims to enhance compliance, reduce tax risks and ensure that profits are taxed where economic activities and value creation occur.
One of the most significant updates in MTPG 2024 is the revised threshold for preparing Contemporaneous Transfer Pricing Documentation (CTPD). Businesses now face clearer distinctions between “minimum” and “full” documentation requirements, along with expanded exemptions for domestic transactions under certain conditions. At the same time, the introduction of a simplified approach for Low-Value Adding Intragroup Services (LVAS) and more rigorous guidance on business restructuring emphasises the importance of accurate and transparent record-keeping for related-party dealings. These changes signal the IRBM’s increased scrutiny on transfer pricing practices to combat base erosion and profit shifting while promoting fair tax practices.
Whether you’re navigating the complexities of new compliance requirements, understanding the implications of stricter arm’s length rules or assessing the impact on your tax strategy, staying ahead of these changes is crucial for businesses in Malaysia.
Join our free webinar, "Mastering Compliance: Insights into the Updated Malaysian Transfer Pricing Guidelines 2024" where our transfer pricing experts will provide a comprehensive breakdown of these updates, their implications and actionable steps to remain compliant. Reserve your spot today and ensure your business is well-prepared for the evolving transfer pricing landscape!
*As an added benefit, all attendees will receive a COMPLIMENTARY Transfer Pricing Self-Assessment Toolkit to help evaluate your compliance with the latest guidelines.