TP FAQs: Positioning of a Single-Function Entity (R&D/Production/Distribution) |单一功能企业(研发/生产/分销)如何定位

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A single-function enterprise is a Malaysian company with restricted functions and risks, such as production, distribution, or contract R&D.

The Inland Revenue Board usually investigates and makes a transfer pricing adjustment because many enterprises, especially single-function businesses, have a mismatch between their functional roles and earnings.

For example, a single manufacturer engaged in processing and manufacturing according to orders from related parties and not undertaking the functions of operational decision-making, product development, and sales should not bear the risks and losses arising from poor decision-making, production shortage and lack of sales of products, and should usually maintain a certain level of profit.

For a loss-making company, the Inland Revenue Board will determine the profit level using economic analysis and comparable pricing or companies.

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