As part of the Budget bill for 2021 (Finance Bill 2020), Malaysia is introducing new transfer pricing penalties that will apply from 2021. This includes the introduction of a new penalty MYR 20,000 to 100,000 for failing to furnish contemporaneous transfer pricing documentation, as well as the introduction of a 5% surcharge on the amount of any transfer pricing adjustments. In addition, new recharacterization powers will be introduced with respect to controlled transactions in order to strengthen the Inland Revenue Board’s ability to adjust aggressive tax planning structures, disregard loans and disallow interest expenses, etc. Further details will be published...