Latest TRANSFER PRICING Books
By Dr Choong Kwai Fatt
3 titles
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Transfer Pricing - Questions and Answers
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Transfer Pricing Methodology - Conceptual Framework
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2023 Malaysian Transfer Pricing Cases
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Transfer Pricing - Questions and Answers
Transfer Pricing – Questions & Answers is a practitioner’s reference text which addresses the most common contentious issues relating to transfer pricing between related companies and the preparation of the needed transfer pricing (TP) documentation.
Answers to a total of 70 questions have been carefully chosen and embedded together with pragmatic advice and suggestions to assist the management of the company in making a better and informed decision with regard to TP matters. Transfer pricing at all times remain a challenging task. It represents an art and never a science. The skillful guidance provided through the Q&A will certainly support the management to strategise, revise and refine the pricing policies between related companies to meet the requirements of the law and avoid unwarranted tax penalties.
The selection of the appropriate TP methodology is crucial and important to explain, support and justify the business transactions between related companies are carried out at market value and in accordance to arm’s length principle. This practitioner text must be used concurrently with the
‘Transfer Pricing Methodology – Conceptual Framework’ in order to have a complete coverage and understanding of the five TP methodologies and their applications as suggested by the OECD model tax treaty.
This is a must-have reference text for every company director involved with business strategies andpricing formulations. It is also indispensable for group accountants, accountants, auditors, tax practitioners, lawyers, company secretaries and every person involved in the preparation of TP documentation.
These 5 cases have been carefully edited and checked as to the accuracy of the contents and also the amount stated relating to the tax, additional tax and transfer pricing disputed sum figures.
Malaysia Courts have vigilantly decided 5 landmark cases during 2022 and 2023. It is important to understand the trite legal principles on TP and the Court's interpretation into the TP legislation. These Malaysian cases have to be completely comprehended in detail fully. The abreast of these case laws would assist in strategising and formulating pricing policies between related companies, confidently in the preparation of the contents of TP Documentation as to the application of FAR analysis and knowing the IRB's interpretation on arm's length principles.
The law is stated as at 1 June 2023
Transfer Pricing Methodology - conceptual framework
Transfer Pricing Methodology – Conceptual Framework sets out the working mechanism and applications of the five transfer pricing (TP) methods that are recommended by the OECD tax treaty model to ensure that transactions between related companies locally and abroad are carried out at 'arm's length'. These five methods are comparable uncontrolled price method, resale price method, cost plus method, profit split method, and transactional net margin method.
The conceptual framework of each method and its methodology are systematically laid out with illustrations and real life applications in explaining, supporting and justifying the business transactions with related companies fulfil the ‘arm’s length’ requirement. Contentious tax issues relating to transfer pricing are included with relevant computations provided to assist in understanding.
The in depth understanding of the TP methodology allows the formulation of TP policy, the drawing up of strategies on pricing decisions, and the preparation of TP documentation to fully comply with various TP legislations under the Income Tax Act 1967, the related PU(A) orders and IRB guidelines. The most appropriate method selected would then be able to accommodate the nature of the business transactions that are carried out between the related companies; support the basis of charging and ensure that the transactions are performed at arm's length within the allowable pricing range. Failure in compliance will result in additional tax being levied during a TP audit plus a penalty for incorrect return up to 100% of tax undercharged, together with a surcharge of up to 5%.
This reference has a total of 14 chapters on the following topics over approximately 276 pages.
2023 Malaysia Transfer Pricing Cases
Malaysia Courts have vigilantly decided 5 landmark cases during 2022 and 2023. It is important to understand the trite legal principles on TP and the Court's interpretation into the TP legislation. These Malaysian cases have to be completely comprehended in detail fully. The abreast of these case laws would assist in strategising and formulating pricing policies between related companies, confidently in the preparation of the contents of TP Documentation as to the application of FAR analysis and knowing the IRB's interpretation on arm's length principles.
These 5 cases have been carefully edited and checked as to the accuracy of the contents and also the amount stated relating to the tax, additional tax and transfer pricing disputed sum figures.