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Malaysia's New Transfer Pricing Guidelines Including Transfer Pricing Documentation and Other Requirements

17 January 2025

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Approved Changes

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Malaysia

The Inland Revenue Board of Malaysia (IRBM) recently updated its transfer pricing guidance webpage with the publication of the Malaysia Transfer Pricing Guidelines 2024, which are dated 24 December 2024. The guidelines, which apply from the year of assessment 2023, are primarily based on the OECD Transfer Pricing Guidelines for Multinational Enterprises and Tax Administrations, with some references to the UN Practical Manual on Transfer Pricing for Developing Countries. The guidelines also incorporate clarifications on the Income Tax (Transfer Pricing) Rules 2023. The guidelines cover: The arm's length principle; Transfer pricing methods; Comparability analysis; Business restructuring; Intra-group services; Cost contribution...