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Transfer pricing and APA Rules issued

25 July 2012

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Approved Changes

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Malaysia

The Income Tax (Transfer Pricing) Rules 2012 (TP Rules 2012) and the Income Tax (Advance Pricing Arrangement) Rules 2012 (APA Rules 2012) both dated 7 May 2012, were issued on 11 May 2012 and are effective retrospectively from 1 January 2009. A copy of the Rules may be obtained from http://www.federalgazette.agc.gov.my/. The key factors are summarized below: Income Tax (Transfer Pricing) Rules 2012 -   Defines contemporaneous transfer pricing documentation. -   Prescribes five transfer pricing methodologies, of which preference is given to traditional transactional methods over transactional profit methods. -   Advocates using a year-by-year comparison when determining the arm's...