Form C YA 2022: Cash Pooling Arrangements and Transfer Pricing
Recent changes to the Form C Recent changes were made to Form C by the Inland Revenue Board in preparation for the YA 2022. One of the most critical changes is for those businesses participating in transfer pricing arrangements. As a result, the disclosure items have been significantly expanded to cover new areas. These new areas include stating the characterisation […]
Form C YA 2022 – Characterisation of Entities for Transfer Pricing Purposes: Service Activities
Recent changes were made to Form C by the Inland Revenue Board in preparation for the YA 2022. One of the most critical changes is for those businesses participating in transfer pricing arrangements. As a result, the disclosure items have been significantly expanded to cover new areas. These new areas include stating the characterisation of your company by reference to […]
Tax Corporate Governance Framework introduced
On April 11, 2022, in response to the growing expectation that organisations in Malaysia will implement governance practices that enhance the accountability, transparency, and integrity of the tax system, the Inland Revenue Board of Malaysia (IRBM) published: This Tax Corporate Governance Framework intends to provide an overview of the IRBM’s expectations on the Tax Corporate […]
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. […]
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 […]
