Malaysia’s transfer pricing (TP) regime has seen sweeping changes between May 2023 and December 2024, marked by the introduction of three key instruments: the Income Tax (Transfer Pricing) Rules 2023, the Malaysian Transfer Pricing Guidelines 2024 (MTPG 2024), and the Transfer Pricing Audit Framework 2024 (TPAF 2024). Together, these introduce more stringent documentation requirements, new safe harbours, and tougher penalties—including the newly operationalised Section 113B administrative penalty.
While the transitional period under TPAF 2024 ends with financial years closing on 31 May 2024, the majority of taxpayers—particularly those with a 31 December year-end—must now prepare for full compliance by August 2025. This includes having contemporaneous TP documentation in place, tested and dated ahead of filing.
Our latest article breaks down this evolving landscape into three parts:
- Three Positive Developments
- Four Heightened Compliance Obligations
- Five Unresolved Issues
With the timeline for Year of Assessment 2024 rapidly approaching, taxpayers are strongly encouraged to begin preparations early to meet the updated requirements.
Access the full article below to explore the details and understand how these changes might impact your TP strategy.