TRANSFER PRICING GUIDELINES - Hasil
This document replaces the 2003 TRANSFER PRICING GUIDELINES . Prepared by the IRBM Multinational Tax Department, the GUIDELINES are intended to help explain administrative requirements pertaining to Section 140A of the Income Tax Act, 1967 and the Income Tax ( TRANSFER PRICING ) Rules 2012. All enquiries may be directed to TRANSFER PRICING GUIDELINES 2012 IRBM TRANSFER PRICING GUIDELINES 2012 INLAND REVENUE BOARD OF MALAYSIA TRANSFER PRICING GUIDELINES TABLE OF CONTENTS PART I PRELIMINARY 1. Introduction 1 2. Objective 1 3. Scope 2 4. Relevant Provisions 3 5. Meaning of Control and Associated 4 PART II THE ARM S LENGTH PRINCIPLE 6. Meaning of Arm s Length Principle 6 7. Determination of Arm s Length Price 8 8. Comparability Analysis 11 9. Factors Determining Comparability 12 10.
IRBM TRANSFER PRICING GUIDELINES 2012 Page 2 of 98 2.2 The Guidelines are concerned with the application of the law on controlled transactions. They provide guidance for persons involved in transfer pricing
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