Transcription of TRANSFER PRICING GUIDELINES
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TRANSFER PRICING GUIDELINES
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.
140A of the Income Tax Act, 1967 and the Income Tax (Transfer Pricing) Rules 2012. All enquiries may be ... control or capital of the other company; or the ... 6.2 The arm's length principle is stated in paragraph 1 of Article 9 of the OECD Model Tax Convention as: "Where . . . conditions are made or imposed between the two
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