Do you need to know more about the latest developments in Transfer Pricing (TP) regulations, specifically Section 113B and Section 140A(3C) of the Income Tax Act 1967 (ITA 1967)?
MIA is organising the Transfer Pricing Conference 2022 to provide guidance for taxpayers who are navigating an increasingly complex and challenging TP landscape. Given the constant changes in tax legislations locally and globally, it can be arduous to ensure that proper measures are taken to ensure compliance with the TP rules at all times.
To make matters more challenging, the Inland Revenue Board of Malaysia (IRBM) is increasingly vigilant in examining taxation matters including TP. Therefore, taxpayers are advised to be diligent and responsible in complying with the latest TP laws and regulations and ensuring that any changes in the TP mechanism are supported with proper documentation and evidence.
To better understand the changes and impacts, do make time for the virtual “Transfer Pricing Conference 2022” with the theme of Ensure Greater Compliance with Transfer Pricing Regulations.
At the TP Conference, participants will get relevant updates on the latest developments in TP regulations, specifically Section 113B and Section 140A(3C) of the Income Tax Act 1967 (ITA 1967). Note that these sections have introduced criminal liability for failure to maintain contemporaneous TP documentation and the imposition of a surcharge on all TP adjustments arising from preparing an incorrect return, irrespective of whether there is tax payable on the adjustments.
So don’t miss out. Come join our expert speakers ranging from tax authorities to recognised tax practitioners who will share their critical insights, guidance, and best practices on the following key topics:
• The Arm’s Length Principle in Transfer Pricing
Discusses the application issues in determining the arm’s length price i.e. the appropriate methods to be applied in a particular set of circumstances and the potential issues arising which may be challenged by the IRBM.
• The Profit Split Methodology
Addresses the transactional profit split method and its technicalities, approaches, benefits, and risks.
• TP Documentation and How to Comply with TP Guidelines
Focuses on tightened TP compliance requirements introduced under Section 113B of the ITA 1967, with effect from 1 January 2021. The TP documentation should be made available within 14 days upon request by the IRBM and applies to TP audit cases which have commenced on or after 1 January 2021.
• IRBM’s Strategies, Actions and Experiences in TP Audit or Investigation (Panel Discussion)
Explains the IRBM’s purpose in conducting TP audits to ensure that taxpayers have complied with TP Rules and Guidelines. Offers an in-depth understanding of why taxpayers are subject to TP audits, the preparations to be made and how to mitigate the risk of being selected for TP audit or investigation.
• TP of Intragroup Financial Transactions
Focuses on intragroup financing and documenting of financial assistance pricing policy. Intragroup financing is a service between associated persons which falls under Section 140A(2) of the ITA 1967, in the form of financial assistance that include loans, interest bearing trade credits, advance or debt and the provision of any security or guarantee.
• Effective Management of TP – TP Dispute Against the IRBM (Panel Discussion)
Provides guidance on management of TP disputes even before a dispute is raised and adoption of best practices for effective management of TP.
• Impact of the OECD’s Two Pillars on the Local TP Regime
Discusses the introduction of BEPS 2.0 (Pillar One and Pillar Two), in particular Pillar Two which is commonly known as the Global Minimum Tax proposal. Pillar Two provides an opportunity for Malaysia to re-assess its non-tax factors and strive harder to ensure that it remains a favoured destination for investments.
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