Minimum Transfer Pricing (MTPD) (Legislation Guide, Organization, Business Overview & Controlled Transactions)

Categories: Courses, Income Tax
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“The fee stated herein is for 3 days package of MTPD workshop”

Taxpayers in Malaysia who have controlled transactions (e.g., buy or sale of goods, providing or receiving services) with associated persons (e.g., group of companies, common directors, partners and spouse/relatives of directors/partners) require to prepare transfer pricing documentation (TPD). LHDN mentioned in the TPD Flowchart that for persons who only engage in domestic controlled transactions, they do not have to prepare a TPD if it can be proven that any adjustments made will not alter the total tax payable or tax suffered by the related persons. But LHDN may still challenge the transfer prices during tax audit and the taxpayers still require to prove the transfer prices are at arm’s length with supporting documents like pricing policy and comparative data.

W.e.f. 1/1/2021, penalty of RM20,000-RM100,000 if you cannot provide transfer pricing documentation (any taxable period) to LHDN upon request within 14 days. However, your business is allowed to prepare Minimum TP Documentation (MTPD), if business annual gross income below RM25 million, and total related party transactions not exceeding RM15 million per annum; or provision of financial assistance not exceeding RM50 million for non-financial institutions.

 

Brochure

— Course Fee: RM 1300.00 (Inclusive of 8% Service Tax) —

What Will You Learn?

  • Know the duty to prepare Transfer Pricing Documentation
  • Understand transfer pricing principles and rules,
  • Update on the latest transfer pricing guide,
  • Gather information about the nature of business and market conditions,
  • Analyse the associated persons relationship,
  • Prepare organization and ownership structure
  • Compile description of the management structure
  • Timeline to submit MTPD
  • The types of common controlled transactions
  • Identified associated persons involved in a controlled transactions
  • Necessary details in contracts, agreements and purchase orders for controlled transactions
  • - Details scope of transactions, timing and frequency
  • - Prepare budget and forecast for controlled transactions

Module 1: Duty to prepare Transfer Pricing Documentation

  • Transfer pricing principles and rules
  • Transfer pricing guides
  • Timeline to submit MTPD

Module 2: Business organization chart

  • Ownership structure
  • Associated persons relationship
  • Stakeholders involvement
  • Management description of the management structure

Module 3: Who are the associated persons

  • Identified the associated persons who are dealing the business
  • Determining their relationship

Module 4: Nature of business and market conditions

  • Business outline, e.g. the industry operated in
  • Analysis of the general economic issues affecting the business when dealing with associate persons
  • Market trend and new development

Module 5: The types of common controlled transactions

  • Sales or purchase of raw materials
  • Services, rent, intangible assets and management fees
  • Interest or guarantee fees

Module 6: Controlled transactions details

  • Description of the controlled transactions (e.g. procurement of manufacturing products, purchase of trading goods, provision of services)
  • details in contracts, agreements and purchase orders for controlled transactions
  • Budget and forecast for controlled transactions
  • Scope of transactions, timing and frequency