Minimum Transfer Pricing (MTPD) (Transfer Pricing Methods & Transfer Pricing Policy)

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 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?

  • Transfer pricing methodologies
  • Formulas and selection process
  • Use transfer pricing policy provide guidelines to set prices for associated parties transactions
  • How pricing policy to dictates the approach taken by two associated parties when determining the price for products or services
  • How to apply the transfer pricing method chosen, e.g. calculations made
  • Transfer pricing strategy

Module 1: Transfer Pricing Methodologies

  • Introduction of 5 common types of transfer pricing methods
  • How to select most appropriate transfer pricing method with regard to the category of transaction
  • the reasons for selecting that method

Module 2: Formulas and selection process

  • Business outline, e.g. the industry operated in
  • Summarise the important assumptions made in applying the transfer pricing methodology.
  • Describe the reasons for concluding that relevant transactions were conducted on an arm’s length basis based on the application of the selected transfer pricing method.

Module 3: Scope of coverage for the business transfer pricing policy

  • A walk through of the business and segments
  • the formula adopted, including anticipated profit margin/mark-up and cost component
  • how the formula is applied

Module 4: Setting of transfer pricing policy

  • Which are the departments that involved to set up and maintain this policy?
  • Determine the resources and tools required to prepare the policy
  • Contingency plan in relation to the setting of the product pricing? E.g. resignation of the key personnel in the pricing setting;

Module 5: How prescriptive should the transfer pricing policy be?

  • Ready supporting documentation to support the setting of product’s pricing
  • Preparation of written procedure on how to select most appropriate transfer pricing method with regard to the category of transaction
  • How frequent is the review of the product pricing been conducted

Module 6: Transfer pricing strategy

  • Is transfer pricing policy in line with the business practice?
  • Closing the gap between TP policy and LTPD
  • Determine prices based on economic value to the customer by using value based pricing
  • How product differentiation for pricing?