Transfer Pricing

24 Feb, 2023, Armada Hotel

IPA Training is Registered with

Learn from the Best

HARI RAMULU MUNUSAMY is a Chartered Certified Accountant, with wide experience in audit private practice and in financial/management/ public sector accounting, auditing and taxation educational process, having been in the profession and industry since October 1974.

 

He started his career with Messrs F. H. Eiles & Co., a firm of Chartered Accountants in London as an Audit Assistant in October 1976. Subsequently, he continued his career as an Audit Supervisor with Messrs Coopers & Lybrand (now known as PricewaterhouseCoopers), Kuantan in May 1984. In January 1986 he joined Messrs Senthe & Co (a firm of Chartered Accountants in private practice in Petaling Jaya), as an Audit Manager, till December 2006. He had also worked as a group accountant for FARMCO Sdn. Bhd. He had also lectured at various institutions of higher learning, as a part-time and full-time lecturer.

 

Over the years, he gained knowledge, experience, skills and expertise in accounting, auditing and taxation related services including tax investigation, forensic accounting and company valuation and floatation.

 

Between 1993 and 2006, he had conducted seminars and courses in financial accounting, internal auditing, external auditing, and taxation to practitioners and
general public. Notable and worthy of mention are taxation seminars for Permodalan Nasional Berhad (PNB), auditing for FELDA, forensic accounting for ROYAL CUSTOMS MALAYSIA, and executive accounting and financial statements analysis course for Pahang ADUNs through Yayasan Pahang. He was the unofficial Consultant to the State Secretary and Chief Minister of Pahang from 1997 to 2000.

 

He is deemed to be a prolific speaker/presenter with excellent commendations from participants, at seminars, workshops, conferences. He has several public appearances relating to taxation, costing, budgeting, financial statements analysis, accounting standards, preparation of financial statements, financial statements fraud, forensic accounting, GST (pre and post implementation), Sales Tax 2018 and Service Tax 2018.


 

Professionally, he is a Fellow member of the Association of Chartered Certified Accountants of UK, a Chartered Accountant of the Malaysian Institute of Accountants, an Associate member of the Malaysian Chartered Institute of Taxation, a Chartered member of the Institute of Internal Auditors of Malaysia (affiliate of USA), an Associate member of the Association of Certified Fraud Examiners of USA, an Associate member of MACFE, member of MATPRO, member of IMA, a member of MAPS, a member of MAPTaC, and a member of Malaysian Institute of Management.

 

His academic qualifications are Diploma in Accountancy (Newcastle-Upon-Tyne, England), and Master of Business Administration (Accounting) from University of Newcastle, USA.

Venue Details

Armada Hotel
Lot 6, Lorong Utara C, Section 52, 46200 Petaling Jaya,, Selangor - 46200
Phone : (603) 7954 6888
Fax : (603) 7958 5593

https://www.armada.com.my/

Contact us

Juliany,
03 2283 6109
juliany@ipa.com.my

Phoebe,
03 2283 6100
phoebe@ipa.com.my 

FOR CUSTOMISED IN-HOUSE TRAINING
Jane,
03 2283 6101
Jane@ipa.com.my

ADDRESS 
A-28-5, 28th Floor, Menara UOA Bangsar, 
No.5, Jalan Bangsar Utama 1, 
59000 Kuala Lumpur
www.ipa.com.my

FOCUSING ON
  • Module 1: Transfer Pricing
  • Module 2: Legal Framework
  • Module 3: Arm’s Length Principle
  • Module 4: Transfer Pricing Methods 
  • Module 5: Specific Transactions
  • Module 6: Applying The Arm’s Length Principle
  • Module 7: Documentation And Penalties
COURSE OBJECTIVE

Transfer Pricing has drawn the attention of tax authorities the world over, and the situation is no different with regards the tax authority in Malaysia. Accordingly, it is important for businesses to understand the fundamentals of the transfer pricing rules in Malaysia.

Participants of this course will therefore be provided with knowledge that cover the importance of transfer pricing, the legal framework, the application of arm’s length principle, the methodologies of transfer pricing, the necessary documentations and the penalties to be imposed from breaches of the law and requirements, as of 30th April 2022.

AFTER ATTENDING THIS COURSE YOU WILL RETURN TO YOUR JOB…
  1. Understanding the importance of transfer pricing to multinational enterprises and SMEs.
  2. Analysing the legal framework of Malaysia for transfer pricing, based on transfer guidelines for Malaysia and OECD.
  3. Understanding the concept of ‘the arm’s length principle’.
  4. Learning the concept of comparability and undertaking comparability analysis and illustrate various transfer pricing methods.
  5. Knowing the issues behind specific transactions.
  6. Understanding the steps to be taken behind documentation for transfer pricing.
WHO SHOULD ATTEND
Accountants, Finance Managers, Staff of Accounting Department, Entrepreneurs, Staff From Operations, Sales, Logistics & Administration
METHODOLOGY
Interactive Lectures, Case studies and Group Discussion. Real-current Transfer Pricing issues will be analysed and scenario solutions will be discussed within the course.
COURSE OUTLINE
9:00

MODULE 1: TRANSFER PRICING  

  • Definition
  • Importance of transfer pricing
  • Importance to know the rules behind transfer pricing


 

MODULE 2: LEGAL FRAMEWORK

  • Malaysian tax environment
  • Malaysian Transfer Pricing Rules
  • OECD Transfer Pricing Guidelines

 

10.45

MODULE 3: ARM’S LENGTH PRINCIPLE

  • Meaning of Arm’s Length Principle
  • Determination of Arm’s Length Price
  • Comparability Analysis
  • Factors determining comparability
  • Comparability adjustments

 

12.00

MODULE 4: TRANSFER PRICING METHODS

  • CUP
  • Resale price
  • Cost plus
  • Profit split
  • Transaction net margin

 

1:00 Lunch
2:00

MODULE 5: SPECIFIC TRANSACTIONS

  • Intragroup services
  • Cost contribution arrangement
  • Intangible properties
  • Intragroup financin

 

3:45

MODULE 6: APPLYING THE ARM’S LENGTH PRINCIPLE

  • The typical process for undertaking a comparability analysis in the Malaysian Transfer Pricing Guidelines 2012
  • Selection of the most appropriate transfer pricing method
  • Arm’s length range

 

 

MODULE 7: DOCUMENTATION AND PENALTIES

  • Retention of records
  • Transfer pricing documentation
  • Penalties 

 

5:00 End of Course