Minimum Transfer Pricing Documentation (MTPD) – Advances or Loan to/from Directors & Intercompany

Categories: Courses, Income Tax
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If you are doing business in Malaysia and having controlled transactions (e.g. buy and sale of goods and providing services) with associated persons (e.g. common directors/major shareholders, partners and relatives) then you need to prepare transfer pricing documentation (TPD).

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 RM15million 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 for financial assistance
  • Understand transfer pricing principles and rules, e.g. Arm’s Length Principle
  • Identified financial assistance controlled transactions
  • Select the appropriate transfer pricing method
  • Identified function and risks of the lender and borrower
  • Prepare pricing policy using template
  • Prepare MTPD by reference to toolkits

Module 1: Financial Assistance

  • Type of Financial Assistance
  • Type of common financial interest in Malaysia
  • Rules of substitution and imputation of Arm’s length Interest
  • Practical Exercise

Module 2: Comparability Study

  • Comparability factors
  • Function and Risk of lender and borrower

Module 3: Transfer Pricing Methodologies for financial assistance

  • Internal & External Comparable uncontrolled price (CUP) method
  • How to determine the arm’s length interest rate for financial assistance
  • Discussion

Module 4: Pricing policy

  • Content of pricing policy
  • Supporting documentation to support the setting of interest rate
  • How frequent is the review of the pricing policy to be conducted

Module 5: Director’s loan/advances

  • Determination of director’s loan/advances as financial assistance
  • What is the arm’s length interest rate for financial assistance to/from director