KCTAN & CO Chartered Accountant

Transfer Pricing Advisory Services

1. Transfer Pricing Policy Development

Identify controlled transactions
Design arm’s length pricing strategies
Draft internal pricing policies aligned with global practices

2. Preparation of Transfer Pricing Documentation (TPD)
We prepare the required contemporaneous documentation to support your pricing, including:

Group Overview and Organizational Structure
Nature and Terms of Related-Party Transactions
Functional and Risk Analysis
Comparable Benchmarking Study
Economic Analysis and Pricing Justification
Local File (required for companies with turnover > RM25 million and related-party transactions > RM15 million)
Master File (for multinational groups with consolidated revenue > RM3 billion)

3. Benchmarking & Economic Analysis

Perform benchmarking using public databases to compare with independent transactions
Select the most appropriate transfer pricing method (e.g., CUP, TNMM, RPM)

4. Transfer Pricing Health Check

Review existing documentation and pricing practices
Identify red flags and risk exposures
Recommend remedial actions and alignment with current rules

5. LHDN Audit & Query Support

Assist in responding to queries from the Inland Revenue Board
Defend transfer pricing position with structured documentation and technical explanation
Liaise with legal and tax counsel where needed

Why Is Transfer Pricing Documentation Important?

Legal Compliance: Mandatory for qualifying companies under Malaysian TP Rules
Penalty Protection: Documentation can mitigate or avoid penalties of up to RM20,000 per year of non-compliance
Audit Readiness: Shows proactive compliance if selected for LHDN audit
Group Transparency: Ensures alignment across global subsidiaries and departments

Who Needs Transfer Pricing Documentation?

Malaysian companies with cross-border related-party transactions
Groups with intercompany loans, royalties, management fees, or shared services
Multinationals with regional headquarters or IP-holding structures in Malaysia
Businesses planning to enter into new intercompany agreements

Our Approach

TP Risk Assessment – Understand your group structure, transactions, and exposure
TPD Preparation – Develop or update documentation in line with the latest Malaysian TP Rules
Benchmarking & Analysis – Support with credible and defensible economic studies
Ongoing Advisory – Monitor new transactions, pricing reviews, and regulatory updates

Stay Ahead of Transfer Pricing Risks

Transfer pricing audits are on the rise in Malaysia. Be prepared, not reactive.

KC Tan & Co is ready to assist you with technical expertise and practical documentation strategies to ensure full compliance and peace of mind.