MALAYSIA TRANSFER PRICING FROM COMPLIANCE TO AUDIT DEFENCE

27 Oct, 2026, Concorde Hotel Kuala Lumpur

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Ms. YONG MEI SIM has over 35 years in Inland Revenue Board of Malaysia (“IRB”) and last held the position as Principal Assistant Director of Penang. She had served with the Payroll Taxes Unit, Field Audit and Desk Audit Unit and actively assisted IRBM’s Federal Councils in handling tax litigation cases.

 

Ms. Yong holds a Master’s Degree in Taxation from the Golden Gate University, U.S.A.

 

Ms. Yong speaks extensively nationwide, sharing her valuable experience and expertise on income tax, service tax and stamp duty updates and other relevant taxation matters.

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

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

Jane,

Office: 03 2283 6101

Mobile: +60 129418251

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
  • 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
INTRODUCTION

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.

AFTER ATTENDING THIS COURSE YOU WILL RETURN TO YOUR JOB…
  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.
WHO SHOULD ATTEND
Directors, CEOs, CFOs, Directors of Finance, Heads of Departments, Tax Managers, Senior Accounts Executives, Supervisors and all Professionals
METHODOLOGY
  • Interactive Lectures
  • Active Interactive Discussion
  • Real-World Case Lessons • Q & A Session
COURSE CONTENT
9:00

TRANSFER PRICING ESSENTIALS

  • Arm’s Length Principle, Controlled Transactions, Related Parties And Substantive Control
9.45

FORM C & DISCLOSURE RISK

  • YA 2025 Disclosure Expectations, Common Mismatch Errors And Domestic Transaction Exposure
10.45

TP RULES 2023 & MTPG 2024

  • Full vs Minimum CTPD, Exemptions, Thresholds And What Evidence Must Still Be Retained
11.45

CONTEMPORANEOUS DOCUMENTATION

  • 14-Day Readiness, Documentation Contents, Penalties, Surcharge And Audit-Ready Files
12.35

FAR, METHODS & BENCHMARKING

  • Characterisation, Functions-Assets-Risks, Method Selection And The Tighter Arm’s Length Range.
1:00 Lunch
2:00

INTRA-GROUP SERVICES & LVAS

  • Benefit Test, Service Evidence, Cost Base, Markup Considerations And SST Implications
3:00

INTERCOMPANY FINANCING

  • Debt vs Equity, Creditworthiness, Interest Benchmarking, Guarantees And Simplified Approaches
3:45

RESTRUCTURING & INTANGIBLES

  • Function Migration, Profit Potential, Exit Compensation, Intangibles And Substance Over Form
4:30

AUDIT, E-INVOICING & DISPUTES

  • Risk Indicators, Audit Process, E-Invoice Consistency, DRP, Appeals, MAP/APA And Case Lessons
5:00 End of Course