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Mastering Transfer Pricing: Regulations & Strategies with Practical Insights

20 Jan, 2026, Concorde Hotel Kuala Lumpur

IPA Training is Registered with

Venue Details

Concorde Hotel Kuala Lumpur
2 Jalan Sultan Ismail, 50250 Kuala Lumpur, Malaysia,

https://kualalumpur.concorde hotelsresorts.com/


Phone : 03 2144 2200

Contact us

FOR COURSE DETAILS

Juliany,

Office: 03 2283 6109

Mobile: +60 122281247

juliany@ipa.com.my

Phoebe,

Office: 03 2283 6100

Mobile: +60 193637822

phoebe@ipa.com.my

Bee Teng,

Office: 03 2282 6112

Mobile: +60 172566121

beeteng@ipa.com.my

FOR CUSTOMISED IN-HOUSE TRAINING

ADDRESS

A-28-5, 28th Floor, Menara UOA Bangsar,
No.5, Jalan Bangsar Utama 1,
59000 Kuala Lumpur

FOCUSING ON
  • Module 1: Understand The Crucial Fundamental Of Transfer Pricing
  • Module 2: Compliance To Prepare TPD And Exemptions Available
  • Module 3: Power Of DGIR And Penalties For Non-Compliance
  • Module 4: The 5 Main Elements You Must Master Before Determining The
    Arm’s Length Price
  • Module 5: Overview Of Transfer Pricing Documentation
  • Module 6: How To Prepare For TP Audit
OBJECTIVES

The objective of this training is to provide an overview of transfer pricing focusing on the latest rules and guidelines in Malaysia, along with practical solutions to navigate the complexities of transfer pricing.

Participants will gain a clear understanding of the critical elements of transfer pricing to effectively implement arm’s length pricing policy for related party transactions, thereby minimizing transfer pricing risks and adjustments.

This training will break down the transfer pricing learning into manageable steps, illustrating how each transfer pricing element inter link to determine the arm’s length price.

Emphasis will be placed on step by step applying the arm’s length principle in accordance with the Malaysian Transfer Pricing Rules 2023 and the updated Transfer Pricing Guidelines 2024. This approach helps participants to comply with regulatory requirements, optimize transfer pricing strategies, and reduce exposure to transfer pricing controversies.

LEARNING OUTCOME

Participants gain a deeper understanding of the core principles and regulatory framework underpinning transfer pricing, including the latest Malaysian rules and guidelines.

They will be equipped to identify and apply the appropriate transfer pricing methods and perform functional and comparability analyses to ensure their related party transactions comply with the arm’s length principle.

The training will empower attendees with practical knowledge on preparing compliant documentation and managing transfer pricing risks effectively.

By the end of the session, attendees will be capable of making informed decisions and taking practical actions to align their business models and transfer pricing strategies in preparing transfer pricing documentation.

WHO SHOULD ATTEND
Directors, CEOs, CFOs, Directors of Finance, Heads of Departments, Tax Managers, Senior Accounts Executives, Supervisors and all Professionals.
METHODOLOGY
Lecture, Active Interactive Discussion, Q&A
COURSE CONTENT
9:00

MODULE 1 – UNDERSTAND THE CRUCIAL FUNDAMENTAL OF TRANSFER PRICING

  • What is a transfer price? What is transfer pricing?
  • What is the meaning of “transfer” from a transfer pricing perspective?
  • “Transfer pricing is an art and not exact science” quoted in Transfer Pricing Guidelines. What does it actually mean in practice?
  • The laws and regulations which
    defined transfer pricing you must not misunderstood.
  • Who are the “associated persons” in a related party transaction.
  • What is a controlled transaction?
  • Is there “controlled” element if there is
    no direct shareholding between the transacting parties?
  • Expounding examples in TPG 2024
  • Types of Controlled Transactions
10.45

MODULE 2 – COMPLIANCE TO PREPARE
TPD AND EXEMPTIONS AVAILABLE

  • The Threshold
  • Identifying Exemptions from preparing a TPD
  • LHDN clarifications on TPD Exemptions
  • What are the new changes in TPR 2023, TPG 2024 and TP Tax Audit Framework 2025
12.00

MODULE 3 – POWER OF DGIR AND PENALTIES FOR NON-COMPLIANCE

  • Disregard Structure of Controlled Transactions
  • Adjustment of Arm’s Length Price
  • Penalties for Non-Compliance
  • Imprisonment of directors
  • Imposition of Surcharge
  • Court Cases
1:00 Lunch
2:00

MODULE 4 – THE 5 MAIN ELEMENTS YOU MUST MASTER BEFORE DETERMINE
THE ARM’S LENGTH PRICE

  • Delineation of Controlled Transactions
  • FAR Analysis
  • TP Methods
  • Comparability Study
  • Arm’s Length Price
3:45

MODULE 5 – OVERVIEW OF TRANSFER PRICING DOCUMENTATION

  • The purpose of a TPD
  • The two elements stated by LHDN -The Double C.
  • Is filling up the Min TPD Template by LHDN sufficient to meet requirements to prepare a transfer pricing document?
  • Essential points in Schedule 1, Full TPD and Minimum TPD.
  • Can you rely on AI to prepare a TPD?
 

MODULE 6 – HOW TO PREPARE FOR TP AUDIT

  • The most important document.
  • Supporting Document
  • Presentation Slides
  • What else?
5:00 End of Course