2022 edition of OECD Transfer Pricing Guidelines
1. The Organization for Economic Cooperation and Development (OECD) announced the release of the 2022 edition of the OECD Transfer Pricing Guidelines for Multinational Enterprises and Tax Administrations on January 20, 2022. 2. The transfer pricing rules serve as a framework for examining transfer prices between associated enterprises, guiding the arm’s length principle implementation. 3. […]
Statement on a Two-Pillar Solution to Address the Tax Challenges – Digitalisation of the Economy
1. On October 8, 2021, the BEPS Inclusive Framework released its latest statement announcing the latest developments in the two-pillar taxation program. 2. The 136 countries and tax jurisdictions that support the latest two-pillar framework include Malaysia, China, Hong Kong, and Singapore, as well as Ireland, Hungary, Estonia, Barbados, and Peru, which had reservations about […]
Multilateral Convention to Implement Tax Treaty Related Measures to Prevent BEPS
1. On 24 November 2016 the Organisation for Economic Co-operation and Development [OECD] published its 15th action plan for the implementation of Base Erosion and Profit Shifting [BEPS] – Multilateral Instrument ]. 2. 18 February 2021, Malaysia deposited its instrument of ratification of the Multilateral Convention on the Implementation of Measures relating to Tax Treaties […]
TP FAQs: Positioning of a R&D Company | 研发企业如何进行功能定位
The R&D environment in Malaysia is evolving steadily, partly because of the increased need for R&D as domestic production capacity increases and partly due to the Malaysian government’s incentives for local R&D and innovation activities. In the post-BEPS (Base Erosion and Profit Shifting) era, the question of how multinational companies should organise their Research and […]
TP FAQs 1: What does “Three-Tiered Approach” to Transfer Pricing Documentation mean?
转让定价同期资料 [Contemporaneous Transfer Pricing Documentation] 概念，源自于20世纪 90 年代初期的美国。 纳税人在与关联方进行交易前或交易时确定关联方交易定价所依赖的文件和信息被称为 “同期转让定价文件“。 为了打击 “税基侵蚀和利润转移” (Base Erosion and Profit Shifting，简称 “BEPS”)，经济合作与发展组织（The Organisation for Economic Co-operation and Development，简称 “OECD”）及二十国集团（英语：Group of Twenty，缩写：G20）在2013年合作制定了一个15点行动计划。 转移定价的文件是这些行动之一的主题，被称为 The concept of Contemporaneous Transfer Pricing Documentation originated in the United States in the early 1990s. Documentation and information that taxpayers have relied upon to determine the […]
