TECHNICAL n BY ABDUL RAZAK RAHMAN WHAT YOU NEED TO KNOW ABOUT THE MALAYSIAN UPDATES TO TRANSFER PRICING GUIDELINES INCORPORATING THE BEPS ACTION PLANS 8 TO 10. TRANSFER PRICING UPDATES The updated guidelines essentially realign the existing transfer pricing (TP) standards to that of the Base Erosion and Profit Shifting (BEPS) Actions 8 to 10 (Aligning transfer pricing outcomes with value creation) and BEPS Action 13 (Transfer pricing documentation and country-by-country reporting). The following are the key points from the session by SM Thanneermalai, Managing Director of Thannees Tax Consulting Services at the MIA Transfer Pricing Conference 2017. CHAPTER II: ARM’S LENGTH PRINCIPLES • Transfer price is acceptable if all transactions between associated entities are conducted at arm’s length price which would have been determined if such transactions were made between independent parties under similar circumstances. • Ensuring that returns are aligned to value creation and not to an entity solely ON 15 July 2017 the Inland Revenue Board Malaysia (IRBM) announced new updates to the Transfer Pricing Guidelines 2012. The updates, which are an expansion of the existing guidelines, are effective immediately and introduce changes to the following chapters: Chapter II: The arm’s length principles Chapter VIII: Intangibles Chapter X: Commodity transactions Chapter XI: Documentation 60 ACCOUNTANTS TODAY | MAR / APR 2018
3
Embed
Transfer Pricing Updates · 2018. 4. 27. · Transfer Pricing Updates The updated guidelines essentially realign the existing transfer pricing (TP) standards to that of the Base Erosion
This document is posted to help you gain knowledge. Please leave a comment to let me know what you think about it! Share it to your friends and learn new things together.
Transcript
C
M
Y
CM
MY
CY
CMY
K
Sigma.pdf 1 26/02/2018 2:42 PM
Te
ch
nic
al
n By ABdul RAzAk RAhmAn
What You Need to KNoW about the MalaYsiaN updates to traNsfer priciNg guideliNes iNcorporatiNg the beps actioN plaNs 8 to 10.
TransferPricing Updates
The updated guidelines essentially realign the existing transfer pricing (TP) standards to that of the Base Erosion and Profit Shifting (BEPS) Actions 8 to 10 (Aligning transfer pricing outcomes with value creation) and BEPS Action 13 (Transfer pricing documentation and country-by-country reporting).
The following are the key points from the session by SM Thanneermalai, Managing Director of Thannees Tax Consulting Services at the MIA Transfer Pricing Conference 2017.
On 15 July 2017 the Inland Revenue Board Malaysia (IRBM) announced new updates to the Transfer Pricing Guidelines 2012. The updates, which are an expansion of the existing guidelines, are effective immediately and introduce changes to the following chapters: