This Seminar is HRDC Claimable
Minimum Transfer Pricing
Documentation
Get Your Practical Guidance To Analyse, Prepare and Writing the Complete Minimum TP Documentation
3 DAYS . Comprehensive TP know-how . 3 q & a SESSIONS
WHERE
The Gardens Hotel, Kuala Lumpur
WHEN
March 2025
9 AM TO 6 PM (21 cpd)
SPEAKER
DR CHOONG KWAI FATT
Master Transfer Pricing:
It is NOW a MUST HAVE SKILL.
Prepare the RIGHT TP DOCUMENTATION
Related party transaction is only secured ONLY
when you have the TRANSFER PRICING DOCUMENTATION.
when you have the TRANSFER PRICING DOCUMENTATION.
Get Minimum Transfer Pricing Documentation – Analysis, Preparation Guidance, Writing to Completion
DO YOU KNOW:
TRANSFER PRICING DOCUMENTATION IS NOW MANDATORY EFFECTIVE FROM YEAR OF ASSESSMENT 2023.
TRANSFER PRICING DOCUMENTATION IS NOW MANDATORY EFFECTIVE FROM YEAR OF ASSESSMENT 2023.
Effective January 1, 2021, Malaysian companies engaged in related party transactions both domestically and internationally must have transfer pricing (TP) documentation. To ensure compliance, TP documentation must be prepared before submitting tax returns starting from the year of assessment 2023.
The Consequences of Neglecting Transfer Pricing Documentation
Failing to have proper TP documentation can have serious repercussions, including:
- Monetary penalties ranging from RM20,000 to RM100,000 if requested by the tax authorities.
- Additional penalties of 30% to 50% for incorrect return submission.
- Risking inadequate TP documentation that does not support your pricing policy, potentially implicating your company.
Whether it’s failing to provide requested TP documentation for related party transactions, missing the 14-day submission deadline to the IRB, or inadequately prepared documentation, companies may face the same consequences.
Minimum TP: Meeting the Threshold
The purpose of TP documentation is to demonstrate that related party transactions are conducted at arm’s length, meaning they are based on market value. For companies with related party transactions exceeding RM15 million and gross income of RM25 million, the IRB has issued a minimum TP documentation template in November 2022 to guide compliance.
Minimum TP vs Full TP: Key Differences
The distinction between Minimum (or Simplified) Transfer Pricing and Full Transfer Pricing Documentation lies in three important analyses. Full TP documentation need to goes the extra mile with three additional analyses:
- An analysis of the nature of the business/industry and market conditions
- Justification for the selection of the transfer pricing method
- Conducting a thorough analysis of functional, asset, and risk identification.
These additional components make Full TP documentation time-consuming and costly. Unfortunately, many providers of Full TP services do a poor job, resulting in inadequate documentation that fails to support a company’s pricing policy and can even lead to legal implications.
The Art of Writing TP Documentation
Crafting comprehensive TP documentation requires expertise and guidance from experienced tax practitioners. After attending Minimum TP by Dr Choong you will know how to:
- Explanations of the conceptual framework, terminologies, and TP methodology
- Assistance in determining the most appropriate pricing method and formulating pricing policies
- Expertise in developing cost apportionment scenarios
Unlock Your TP Documentation Skills with Dr Choong
Join our three-day practical workshop designed to equip you with the necessary knowledge and skills to confidently write and complete minimum TP documentation. We cover various scenarios, including management services, trading companies, construction and property development firms, intercompany loans and many more.
Latest knowledge to write comprehensive and customised minimum TP documentation that adheres to the Income Tax (Transfer Pricing) Rules 2023 and Transfer Pricing Guidelines 2012 (updated 2017).
Don’t leave your TP documentation to chance.
Now you have the TP Documentation skills, to navigate the complexities of related party transactions and ensure tax compliance in an efficient and effective manner.
Comprehensively covers Minimum Transfer Pricing.
Must-Have even for those who Review Transfer Pricing Documentation
Attention all company accountants and decision-makers in Malaysia! Listen up, because we’ve got important news for you. The government now requires Minimum Transfer pricing documentation as a compulsory tax requirement. Don’t know much about transfer pricing? Well, it’s time to get in the know, because here’s why:
- First off, this is a brand new law. That means everyone is starting on a level playing field, so external consultants may not be as valuable in the upcoming year. With so much work to be done, many companies are opting for a review basis instead.
- Even if you do outsource some of the work, the input still needs to come from someone within the company- like you!
- This new requirement also means that transfer pricing skills are here to stay. Related party transactions are becoming increasingly common, given the government's focus on incentivising SMEs. Companies are prone to shifting to decentralised structures, which can be tricky to navigate. Don't get left behind- as a decision maker or advisor, transfer pricing know-how is now a Must. So, brush up on your TP knowledge and keep your company compliant.
SO DON’T MISS OUT ON THIS AMAZING OPPORTUNITY TO LEVEL UP YOUR TRANSFER PRICING SKILLS!
WHEN YOU ATTEND THIS SEMINAR. YOU GET THE COMPLETE COVERAGE OF transfer pricing.
Mastering Transfer Pricing is a life time skills. Lack of Transfer Pricing skill is a pricey cost to pay. Especially since IRB now require taxpayer to declare in their Tax Return Form whether they have related party transaction and transfer pricing documentation. Ability to compile Transfer Pricing Documentation is a recurring and ALSO an essential skill.
Each Related Party Transaction Needs a Set of "Pricing Method"
Dr Choong especially creates this Minimum Transfer Pricing 2023 for participants so that participants know clearly whether you need to prepare a transfer pricing documentation or not. If yes, which pricing methodology to utilise and what are the supporting documents needed to bundle together with your Transfer Pricing Documentation.
Mastering how to set “Pricing Policy” sounds like a tricky and abstract concept, but it’s actually a VERY Practical and Useful concept. It provides you the financial mind and sharpness that you need when there is any price dispute (be it internally or when disputed by IRB).
We are eager and look forward to seeing you in this Live in The Gardens Hotel. Network with peers and client, while resolving your tax concerns.
TP Topics Covered
- TP on Services
- Proprietary Rights
- Patents
- Royalty
- Licensing fee
- Rental, lease of asset
- Minimum TP Doc
- Trading company
- Distributor
- FAR analysis
- Pricing policy
- Loan and advances
- Interest income
- Deemed interest income
- Loan from related companies
- Source of loan to associate person
- Malaysian company v Overseas company
- Withholding tax implications on loan from overseas
- Earning stripping rules on loan
what’s covered
Bold
Content
Contents includes Tax Updates & Tax Planning but are not limited to just the following:
DAY ONE - 6 MARCH 2024
– Mastering TP Documentation: Understanding Responsibilities and Thresholds
- (a) Who is Responsible for TP Documentation Preparation?
- (i) Service provider or service recipient?
- (ii) Investment holding company or subsidiaries?
- (iii) Property developer or contractor?
- (iv) Lender or borrower?
- (v) Payment on behalf?
- (b) How to Determine the Threshold of Annual Turnover: RM25 million?
- (i) Gross or net business income?
- (ii) Inclusive of investment income and other income?
- (iii) Measuring sale of business, company restructuring
- (iv) Including gains on disposal or realization of investments?
- (v) Consideration of change in accounting date with YA >12 months
- (c) Understanding Related Party Transactions of RM15 million
- (i) Scope and assessment method
- (ii) Defining related party or connected persons
- (iii) Handling hybrid situations with related party transactions
- (iv) but gross income < RM25 million
- (d) Exploring Controlled Persons and their Differentiations
- (i) Scope and distinctions with related parties, connected persons, and relatives
- (ii) Control, deemed control, and common control scenarios and applications
- (e) Categories of Controlled Transactions
- (i) Business
- (ii) Investment
- (iii) Other income
- (f) Understanding the Arm's Length Range and Its Importance in Pricing Policy Formulation
- (i) Understanding the meaning and importance
- (ii) Implications of market value in pricing policy formulation
- (iii) Methods for determining arm's length
- (g) Breakdown of TP Terminology for Clarity
- (i) Sample, median, interquartile 37.5 and 62.5
- (ii) Understanding the arm's length range
- (h) Comprehensive Overview of TP Methodology and Which Method is Suitable for Different Types of Transactions
- (i) Comparable uncontrolled price method
- (ii) Resale price method
- (iii) Cost plus method
- (iv) Profit split method
- (v) Transactional net margin method
- (i) The Importance of Pricing Policy Formulation and Guidance on How to Write It
- - Analysing functions, assets, risks, and economic circumstances
- - Guided approach with provided templates
- (j) Walkthrough Guidance on Minimum TP Documentation
- - Company information and group structure
- - Assessing risk for Malaysian and overseas companies
- - Description of management
- (k) Noting Points for Form C Disclosure on TP: Your Step-by-Step Guide
DAY TWO - 7 MARCH 2024
FOCUS ON TP IN THE SERVICES INDUSTRIES
- (a) Understanding TP for Investment Holding Companies and Their Services
- - Basis of charging services
- - Sharing costs with or without margin
- - Correct accounting treatment for payments on behalf
- (b) Determining the Right Basis of Charging for Management Service
- (i) Management services
- (ii) IT solutions and support
- (iii) HR and legal
- (iv) Accounting and Administrative
- (v) Advertisement and promotion
- (vi) Marketing
- (vii) Training services
- (viii) Research & development
- (c) TP Considerations for Property Developers and Construction Companies
- - Revenue Division and Payment on Behalf Treatment
- (d) TP Treatment for IT Solution Companies in Joint Projects and Secondment of Staffs
- - Basis for joint projects and collaboration
- - Allocation of costs and secondment of staff
- (e) Managing TP in Trading Companies with Overseas Inventory Purchases
- - Acceptable GP margin by IRB
- - Resale price method and selection of products
- - Formulating arm's length transactions with customers
- (f) TP Insights for Engineering Companies and Correct Cost Component Computations
- - Joint projects and cost plus method
- - Accurate computation of cost components
- (g) TP Considerations for Medical, Healthcare, and Dentistry Practices : Cross-Services and Bulk Purchases
- - Cross-services between common controlled companies
- - Bulk purchase and equipment allocation between related companies
- (h) Exploring TP for Overseas Payments: Royalties and Special Classes of Income
- - Charging basis and transfer pricing documentation
- (i) TP Documentation for Rental of Immovable Property and Lease Rental of Movable Property:
- - Charging and Cost Sharing
- - Proper documentation and invoice description
- (j) Detailed Minimum TP Documentation Guidance and Sample Templates for Services
DAY TWO - 8 MARCH 2024
FOCUS ON TP IN THE SERVICES INDUSTRIES
- (a) Understanding the annual threshold of RM50 million
- - Computation of the threshold and assessment of the company
- - Documentation requirements for loan substantiation
- - Practical exercises for hands-on learning
- (b) Explore TP Terminology and its scope, covering topics such as:
- - Differentiating between loans, advances, and payments on behalf
- - Exploring share capital, including ordinary and redeemable preference shares
- - Understanding financial assistance
- - internal vs. external finance
- - Delving into Deemed interest income
- - interest restriction
- - Director and its related parties
- - Must prepare Agreement or no agreement: stamped or not stamped ?
- (c) Learn about loans FROM directors or shareholders, including:
- - Charging interest or considering interest-free options?
- - Formulating the right interest rate
- - Documentation requirements to support this loan
- - Gaining perspective on deductions from the company's standpoint
- (d) Discover the implications of loans or advances to directors:
- - Understanding deemed interest income and its consequences
- - Utilising the average lending rate
- - Exploring director's perquisites
- - Understanding computation and practical applications
- (e) Explore the differences between intercompany loans, advances, and payments on behalf:
- - Determining whether to charge interest or offer interest-free options
- - Assessing TP audit risk on Deemed Interest Income
- - Formulating interest rates
- - Understanding interest restriction applications
- (f) Navigate the complexities of loaning to overseas related companies:
- - Understanding the implications of foreign source income
- - Making judgment calls on income received in Malaysia
- - Implication of "timing" receive into Malaysia
- - Computation of unilateral and bilateral relief
- (g) Discover the intricacies of loans from overseas holding or related companies:
- - Assessing the necessity of charging interest
- - Navigating withholding tax applications
- - Understanding TP documentation for interest expenses to overseas entities
- - Exploring the potential of Earning Stripping Rules
- (h) Consider the alternative of investing in shares instead of intercompany loans:
- - Assessing the pros and cons of this option
- - Exploring redeemable preference shares and their implications
- - Gaining perspective on the income tax and accounting aspects
- - Investigating the truth behind dividends as interest expenses
- (I) Finally, learn how to effectively document your intercompany loans with our comprehensive template.
JOIN THIS SEMINAR.
Grab these rare Minimum Transfer Pricing 2024, ability to review and prepare the min tp documentation.
WHAT PAST PARTICIPANT THINKS
ABOUT OUR SEMINAR LAST YEAR
REVIEW
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Timeline
The estimated timeline for MINIMUM TRANSFER PRICING 2024
DAY ONE - 6 MARCH 2024 (WEDNESDAY)
Part 1
12:30 PM TO 1:30 PM LUNCH BREAK
Part 2
Part 3 (Questions & Answer) 6:00 PM TO 7:00 PM
…. More content may be added as changes where relevant from Minimum Transfer Pricing 2023 prior to event date.
DAY TWO - 7 MARCH 2024 (Thursday)
Part 1
12:30 PM TO 2:00 PM LUNCH BREAK
Part 2
Part 3 (Questions & Answer) 6:00 PM TO 7:00 PM
…. More content may be added as changes where relevant from Minimum Transfer Pricing 2024 prior to event date.
DAY THREE - 8 MARCH 2024 (Friday)
SPECIAL CONTENT : Financing: Intercompany Loan and Advances to/from Directors
Part 1
12:30 PM TO 2:00 PM LUNCH BREAK
Part 2
Part 3 (Questions & Answer) 6:00 PM TO 7:00 PM
…. More content may be added as changes where relevant from Minimum Transfer Pricing 2023 prior to event date.
JOIN THIS SEMINAR.
Grab these rare Minimum Transfer Pricing 2024, ability to review and prepare the min tp documentation.
Venue
Conducted in the ballroom within the relaxation of The Gardens Hotel , 5-star heaven along Federal Highway (near Kuala Lumpur). Within the vicinity of Midvalley and The Gardens Mall. With a selection of 3 hotels within walking distance. It is of great comfort if you are travelling from outstation. In addition, The Gardens Hotel is with direct access to network of train via KTM and LRT (Abdullah Hukum Station).
Address:
The Gardens, Lingkaran Syed Putra, Mid Valley City, 59200 Kuala Lumpur
What you will get :
- The reference books and FULLY printed slides,
- The Q & A link to submit your questions: Prior, During and Post seminar.
- Certificate of Attendance (Pdf) – 21 CPD
JOIN THIS SEMINAR.
Grab these rare Minimum Transfer Pricing 2024, ability to review and prepare the min tp documentation.
PRICING
Choose the right category based on the number of participants.
Group of
1 - 2 Pax
RM
4,200
-
Sign this up for the amazing Minimum Transfer Pricing Course!
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Here’s how the math works :
RM 4,800 - RM 600 Early Bird Discount
REGISTER 1 - 2 PAX
Seat are limited and subject to first come, first served basis.
Group of
3 - 4 Pax
RM4800
RM
3,900
-
Sign this up for the amazing Minimum Transfer Pricing Course at discount of RM 300 each!
-
Here’s how the math works :
RM 4,800 - RM 600 Early Bird Discount -RM 300 group registration
REGISTER 3 - 4 PAX
Seat are limited and subject to first come, first served basis.
Group of 5 Pax
& more
RM4800
RM
3,600
-
Sign this up for the amazing Minimum Transfer Pricing Course at discount of RM 600 each!
-
Here’s how the math works :
RM 4,800 - RM 600 Early Bird Discount -RM 600 group registration
REGISTER 5 PAX & MORE
Seat are limited and subject to first come, first served basis.
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wHO IS IT FOR?
Created for Business Owners, Accountants, Financial Personnel, Company Directors and you of course.
ACCOUNTANTS, FINANCIAL CONTROLLERS, SENIOR EXECUTIVES
Attention Accountants, Financial Controllers, and Senior Executives! Are intercompany loans, director advances, shared services, or purchases a common part of your business transactions? Then listen up, because the tax officer’s focus for 2023 is on Transfer Pricing.
Navigating new MFRS and SST can be tough enough, but transfer pricing takes it to a whole new level of complexity. That’s why we’ve created this seminar specifically for you. Gain comprehensive knowledge and be confident in your pricing methodology, backed up by the right documentation.
Our new government’s tax policy is shining a spotlight on related party transactions for the next 5 years. While minimum transfer pricing may not be as meticulous as full TP documentation, it’s definitely doable if you learn the skills now.
Discover how this will impact your business direction, accounting entries, and documentation going forward. Don’t let compliance requirements and thresholds catch you off guard. There’s plenty of work to patch up on the missing TP Skills NOW.
BUSINESS AND FINANCIAL DECISION MAKERS
Attention all CEOs, CFOs, General Managers, and Financial Controllers! Whether you choose to tackle it in-house or outsource it, the responsibility ultimately falls on the Financial Decision Maker to review the TP document.
TP may be new to even the Tax Agent, who simply doesn’t have the time for detailed work. Just like with GST, decision makers like yourselves need to step in and take action before it’s too late. Let’s get things done!
SHAREHOLDERS AND DIRECTORS
Managing the Company: Who’s Involved?
When it comes to setting prices for related companies, the Directors are the ones in charge. Making sure you know the right pricing methodology is crucial for managing transfer pricing risks effectively.
However, being a Shareholder or Director also means there are personal risks involved. These risks include travel restrictions, personal liability to pay for any tax undercharges, and even the possibility of the company going bankrupt. It’s important for Shareholders and Directors to have a clear understanding of these risks and ensure the right safeguards are in place.
To stay ahead, it’s crucial to stay informed about the latest risks and take advantage of opportunities for tax incentives, business recovery, corporate restructuring, and tax planning. This applies to all industries.
At the end of the day, being proactive and knowledgeable about the risks and opportunities can make a significant difference in successfully managing the company.
IT'S HAPPENING THIS SEPTEMBER. SO THAT YOU CAN HAVE ALL YOUR TAX CONCERNS SETTLED BEFORE SUBMITTING YA 2023 TAX SUBMISSION.
INTERESTING FACT
93% of our Participants consist of Senior Management and Key Decision Makers.
Here's 2 main reasons why management Level love our seminar :
Concise & Packed with practical "How to"
Experienced Senior Management appreciate the fact that the more they legally slash from Tax, the more Profit they can easily retain in the company.
We Cover Risk Management
Tax Risk Management is on the shoulder of Senior Management (especially Directors), compliance and right documentation free them from lots of Tax Headache and be confident when they faced with Tax Audit and Investigation.
[One Last Secret: We notice most of our frequent attendees get promoted Very Fast in their respective Company. I suppose, those who can create high impact on company's $$$ will tend to get priority to be headhunted for promotion when it is available.]
Dr Choong Kwai Fatt
Dr Choong Kwai Fatt is an acknowledged tax authority and a leading tax specialist in Malaysia, highly sought after speaker and provided tax consultancy services to listed companies, audit firms, legal firms and the Malaysian Government for more than 25 years.
Like a diamond with multiple façade, Dr Choong shines for his depth of tax knowledge, rare combination of skill and experience derived from being a speaker, writer, researcher, advocate and solicitor, consultant and his passion towards tax education.
Collectively this has resulted in his outstanding presentation skill and charming persona as a speaker and advisor.
5/5
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faq
Most frequent questions we received.
Unfortunately, most of the sessions will not be repeated. Should there be a similar session, you can change to other session of the same event, subject to availability.
Refund is not possible as all seating arrangement with venue and printing of materials have been arranged and put in place. However, we can accept replacement by informing us via email 5 days prior to the event.
Yes. This seminar does not just cover the surface Updates or Latest Developments, it covers the most crucial question : “How to implement and embed them into my Company System?”
Join Us and Expect to take away How Practical Solutions and Implementation Pointers.
Our budget seminar is popular because we cover TAX PLANNING.
Conventional Budget seminar are created with the objective of just updating participants on latest changes.
Knowing tax changes help you to remain compliance.
Knowing tax planning provides substantial TAX SAVING.
No. The CPD stated on the Certificate of Attendance is as awarded by the Training Provider in recognition of the hours spent learning with the respective Speaker/ Trainer.
Unfortunately, it is subject to the discretion of the respective institution whether or not to accept the point or otherwise.
Yes, we do understand plans are always subject to change. Do provide us the name 3 Days prior to the event date.
No. We wish we can answer yes to this. Our Seminar is based on latest and most up to date information, rules and regulations, with a cut off point of 1 to 2 weeks before the event. The earliest date for us to get the seminar materials from the Trainer/ Speaker is 1 – 2 days prior to event date. In this regards, we will have to turn down all request to deliver materials prior to event date.
We distinguish ourselves based on three areas. We are specialist in arranging effective and quality tax seminars. Has been doing this since 2013.
We are also a reputable seminar organising company, specialised in organising Advanced Tax Planning programs. Our motto is to encourage the policy of “Plan Your Tax, NOT Need to Evade Tax.”
Our Participants mainly consist of Corporate Leaders, Practitioners and Senior Executives, we hold firm to the view that we must do all it takes to maximise learning and impact in a minimum amount of time. We take pride in providing the most updated and well researched information.
Yes, our events are HRDF Claimable*
(*Subject to PSMB’s approvals by Participants). However do note that HRDF has guideline on the claiming of HRDF, where limits to RM1,300 per day for physical live seminars, while online training is limited to RM700.
This applies to Company that is contributing to HRDF Fund.
Usually for live training as per the information we gather from Participants over the years, register and get the Invoice first.
Then, together with the Brochure, submit both Invoice and Brochure to HRDF for pre-approval (usually takes about 3 to 5 working days). Make sure you select the 30% upfront payment.
Once pre-approved, kindly email the preapproval for our record.
Post seminar we will submit the claim from PSMB after participants attended the event.
For Online training, HRDF do impose additional criteria. Such as the minimum number of hours and the minimum number of days and maximum number of participants per session. Do check with HRDF for more information on this.
If you have the latest updates as to how to claim HRDF, please do share with us via event@synergytas.com.
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We provide both. View them online or the download pdf version.
