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Malaysia Transfer Pricing Guidelines Updated to Reflect BEPS Project Outcomes including Master File Requirements

13 July 2017

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Approved Changes

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Malaysia

The Inland Revenue Board of Malaysia (IRBM) has published updates to the 2012 Transfer Pricing Guidelines that reflect the outcomes of the OECD BEPS Project, including with respect to BEPS Actions 8 to 10, and Action 13. Updates have been made to the following chapters of the guidelines: Chapter II - The Arm's Length Principle, which includes that the application of the arm's length principle will mainly focus on achieving transfer pricing outcomes that are in line with value creation, and the addition of a risk analysis framework setting out the process or steps for analyzing risk in a controlled...