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In today’s post Base Erosion Profit Shifting (“BEPS”) world, the introduction of BEPS Action 13 (Transfer Pricing Documentation and Country-by Country Reporting) has reformed the transfer pricing landscape. There is collaboration amongst tax authorities worldwide for mutual exchange of information and increased transfer pricing transparency. Malaysia is no exception as the Malaysian tax authority continuously reinforce the existing transfer pricing rules and regulations.

With this, the burden to prove the economic substance of controlled transactions (commonly known as related party transactions) with the arm’s length principle is now a greater responsibility for taxpayers.

How KPMG can support you

We at KPMG in Malaysia has a specialized pool of well-equipped transfer pricing professionals providing a holistic transfer pricing services, from planning up to managing compliance and documentation obligations for all taxpayers, be it multinational entities or local conglomerates. Leveraging vide our global network, we offer modern tools and bespoke solutions to meet each taxpayers’ needs.

We work hand-in-hand with the taxpayers to navigate the proliferation of BEPS-transfer pricing requirements with systematic approaches:

Our Transfer Pricing Approaches


Our Transfer Pricing Services


A spotlight on Operational Transfer Pricing (“OTP”)

As the global economy expands into every corner of the world, organizations today constantly adopts complex business models with evolving intercompany arrangements, owing to intensified demand for a greater tax transparency. How can you achieve effective transfer pricing management in this current environment?

OTP is the management of transfer pricing data, technology, processes and people. At KPMG, our OTP is a revolutionary blueprint designed to drive the alignment of transfer pricing with your business strategies, operations, processes, and governance. With OTP, we turn strategies intent into operational reality.

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