MODULE 1: TRANSFER PRICING TERMINOLOGY

• What is Transfer Pricing?
  
• Material Changes
  
• Transfer Pricing Adjustment
  
• Arm’s length principle
  
• Definition of Related Party & Relative
  
• What are Associated Enterprises (AEs) / Related Party?
  
• Comparability, functional and risk analyse.
  
• Pricing Policies
  
• Benchmarking analysis
  

MODULE 2: DEALING WITH IRB

• Common Grounds of Disputes with IRB
  
• Avoiding disputes
  
• Challenges faced by taxpayers.

MODULE 3: PRACTICAL ISSUES ON TRANSFER PRICING

• What are the Main focus areas by IRB in a TP Audit?
  
• How can I comply with the Transfer Pricing Rules?
  
• How often should the contemporaneous transfer pricing documentation be updated?
  
• What is a Transfer Pricing Audit?
  
• What is Contemporaneous Transfer Pricing Documentation?
  
• How to demonstrate that intra-group services are conducted on an arm’s length basis?
  
• Why are intercompany agreements important?
• How to prepare a good TP documentation?
  
• What are currently the main TP areas of scrutiny by the tax authorities in your country?

MODULE 4: TP DOCUMENTATION CHECKLIST

• Organization structure
  
• Nature of business or industry & market conditions
  
• Controlled transactions
  
• Pricing Policies
  
• Comparability, functional, assets and risk (FAR) analysis
  
• The selection of the transfer pricing method
  
• Methodologies for Transfer Pricing
  
• Supporting documents in developing the TP analysis
  
• Index to documents

MODULE 5: CASE STUDY- RELATED PARTY TRANSACTIONS

• Related Party Transactions (RPT)- IT services
  
• Related Party Transactions (RPT)- Rental
  
• Related Party Transactions (RPT)- Intragroup financing

MODULE 6: TAX ALLOWABLE & DEDUCTIONS

• Allowable expenses
  
• Non-allowable expenses
  
• Special Deduction
  
• Double Deduction
  

MODULE 7: UNDERSTANDING TAX & TAX PLANNING

• Income tax computation
  
• Non allowable deduction
  
• Special deduction
  
• Double deduction
  
• Capital allowance.
  
• Approved Donation
  
• Tax rate
  
• Use financial tools of goal seek & solver to meet management tax planning & cash flow position.

MODULE 8: FINANCIAL & ACCOUNTING DOCUMENTATIONS

• General principles of taxability
  
• General principles of deductibility
  
• Capital vs Revenue in nature
  
• Tax treatment on expenditures for Repairs & renewals of assets
  
• Cost of renovation & refurbishment of business premise) Rule 2020
  
• Eligible Cost- first schedule
  
• Role of Bank Statements, Receipts, Bills, Vouchers, Agreements.

MODULE 9: DISCUSSION ON TAX AUDIT ISSUES

• If company loan to another company its deemed interest needed? And what rate should we charge
  
• My company YE 31 Jan. on 31 Jan 2020, we accrue for director fees and staff bonus but due to covid 19, balance of the accrual, can we defer payment to dec 2021 or Jan 2022?
  
• Director’s loan to company to cover MCO period cash flow problem, require charging interest to the company?
• If I owned a property and I appoint an agent to manage it and pay commission to him. Do I have to declare this commission?
  
• The company bought medical card for directors and managers. In YA 2018, one of the directors had treatment of heart. The insurance compensation will not be taxable right? Since it is an added back item.
  
• We bought PA insurance for our staff. If one of our staff pass away and we claim the insurance company. Is it taxable?
  
• The company received compensation from government for compulsory acquisition of company business location to cover for the income loss. Is this compensation taxable?
  
• What if no building being reconstructed?
  
• How about compensation for burglary in office? Do we need to pay tax for compensation received?
  
• When LHDN in their desk audit request for creditor ledger & creditor aging report, can I know what are they looking for and for what purpose?
  
• Is sole proprietor & partnership company entitled to claim RM 300,000 renovation cost?
  
• The Company rent a land and build a modular container store to increase the storage capacity. can I claim the RM300K?
  
• Is electrical installation for new incorporate of company qualify as renovation?
  
• Data Relationships, Income Tax Computations, Related Party Transactions.

MODULE 10: ISSUES RAISED BY INLAND REVENUE

• Sole proprietor & partnership company had a company trip & do we need to add back the sole proprietor & partnership portion for tax purposes? Is leave passage & company trip different and what about directors all need to add back?
  
• If staff purchase handphone cost RM3K, company only reimburse RM2K. Is RM2K exempted from tax?
  
• Working director with controlling interest cannot enjoy the allowance. How do company cover the expenses incurred by him/her for business like handphone, petrol, tolls etc.
  
• Can employee medical card be charged out as expenses by company?
  
• Is meal allowance paid to employees for outstation trip exempted? Do we need to include in FORM EA?
  
• Should we declare all director’s expenses as company expenses without including the amount in the form EA?
  
• There is no of years director fee remain unpaid in the accrual account. We want to settle in this current year. Will it be any issue when we payout and report in the director current YA (BE)?
  
• How to treat overprovision of director’s fee in the following year? For example, RM100,000 provided in 2019 but paid RM40,000 in 2020
  
• Can the company get full deduction when we claim mileage reimbursement?
  
• Verification of Amount Declared from accounts, records, bank statements, etc.
  
• Prepare you for the tax audit or tax investigation process
  
• Gather and evaluate critical feedback