• Transfer Pricing Essentials
• Form C & Disclosure Risk
• TP Rules 2023 & MTPG 2024
• Contemporaneous Documentation
• FAR, Methods & Benchmarking
• Intra-Group Services & LVAS
• Intercompany Financing
• Restructuring & Intangibles
• Audit, E-Invoicing & Disputes

Equipping participants with a practical, audit-ready understanding of Malaysian Transfer Pricing - from the arm’s length principle and Form C disclosure to contemporaneous documentation, benchmarking, intercompany services,financing, restructuring and dispute management.

Participants will learn how to identify high-risk transactions, strengthen supporting evidence and defend pricing positions under IRB scrutiny.

1. Understanding the latest Malaysian Transfer Pricing requirements under the TP Rules 2023 and Malaysian Transfer Pricing Guidelines ( MTPG) 2024, and how they affect your organisation.
2. Identifying Transfer Pricing risks before they become audit issues, particularly those arising from related-party transactions, Form C disclosures and inconsistencies in supporting information.
3. Knowing whether your organisation requires full or minimum Contemporaneous Transfer Pricing Documentation (CTPD) and what supporting evidence must still be maintained where exemptions apply.
4. Being better prepared for IRB scrutiny by maintaining contemporaneous, organised and audit-ready Transfer Pricing documentation within the required timeframe.
5. Applying FAR analysis more effectively by assessing the functions performed, assets employed and risks assumed by related entities to support appropriate transaction characterisation.
6. Selecting and supporting appropriate Transfer Pricing methods and benchmarking approaches to demonstrate that related party transactions are conducted at arm’s length.
7. Strengthening the documentation of intra-group services, including the benefit test, evidence of services rendered, cost allocation, mark-ups and relevant SST considerations.
8. Assessing intercompany financing arrangements more confidently, including debt versus equity, creditworthiness, interest benchmarking, guarantees and supporting documentation
9. Recognising Transfer Pricing risks arising from business restructuring and intangibles, including function migration, profit potential, exit compensation and substance-over-form considerations.
10. Improving consistency between Transfer Pricing documentation, Form C disclosures and E-Invoicing records, reducing mismatches that could attract IRB attention.
11. Recognising key Transfer Pricing Audit Red Flags and preparing stronger supporting evidence to substantiate and defend the company’s pricing positions during an IRB audit.
12. Understanding the available options for managing Transfer Pricing Disputes, including the Dispute Resolution Proceeding (DRP), appeals, Mutual Agreement Procedure (MAP) and Advance Pricing Arrangements (APA).
13. Reducing exposure to Transfer Pricing adjustments, penalties and surcharges through better documentation, stronger internal controls and earlier identification of compliance gaps.
14. Returning with a Practical Transfer Pricing Audit-Defence Mindset—better equipped to review your organisation’s related-party transactions, identify weaknesses and take corrective action before an audit occurs.

• Interactive Lectures
• Active Interactive Discussion
• Real-World Case Lessons • Q & A Session