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Transfer Pricing Audit Framework 2019

Transfer Pricing Audit Framework 2019

The Malaysian Inland Revenue Board (“MIRB”) released the Transfer Pricing (“TP”) Audit Framework 2019 (“TPAF 2019”) to replace the 2013 version (“TPAF 2013”) effective 15 December 2019.

Highlighted below are some of the key points from the TPAF 2019:

In addition to the details above, the framework also emphasizes on the new penalty rates as follows:

Please keep in mind that the TPAF 2019 also specifically discusses the consequences of requesting for extension of time for submission of TP documentation. Even though taxpayers have successfully obtained the extension of time, it will still be deemed as late submission as taxpayers failed to submit within the stipulated time frame of 30 calendar days.

Based on the above, it is evident that the TPAF 2019 is MIRB’s attempt to emphasize compliance and introduce tighter deadlines for taxpayers to submit the relevant documents and information.  Hence, taxpayers are encouraged to ensure that the TP documentation and other information is prepared in a timely manner and are readily available for submission.


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