TRANSFER PRICING IS AN IMPENDING MAJOR TAX CHALLENGE FOR COMPANIES ESPECIALLY MULTINATIONALS

Recently,one of the big four international accounting firm Ernst &Young has conducted a survey on transfer pricing

According to the survey,

There is a dramatic increase in the scope of Transfer Pricing documentation required by governments with penalties imposed more frequently and at higher levels when multinationals get it wrong. Governments are constantly [...]

WHAT IS ARM’S LENGTH PRINCIPLE AND WHAT ARE THE METHOD TO DETERMINE ARM’S LENGTH

Arm length transaction is a very hot topic in transfer pricing. This article seeks to explain what it means “ at arm length and what are some of the traditional methods to determine “ arm length” 

“ At Arm Length”  means that a transaction performed within a company must be priced as if carried out [...]

A Comprehensive List of Management Services

CLICK TO THE MAIN PAGE FOR ALL ARTICLES ON SHARED SERVICE CENTRE 

Further to my earlier article on management fee/transfer fee and the type of management services to be rendered,append below is a very comprehensive list of management services issued by our Malaysian Custom Authorities who is also in charge of the service tax:

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Drafting/Formulating Management Services As Part of Management Fee/Transfer Pricing Strategy

If we noticed that many companies charge management fee as part of the transfer pricing strategy. So what type of services can we name so as to able to justify charging management fee?

Append below are examples that you may considered to draft as management services for charging the management fee. The quantum and justification [...]

Transfer Pricing Systems:Methods &Selection(Part C)

a) Comparable Uncontrolled Price (CUP):- This method seeks to determine the ALP by comparing the controlled transaction with the uncontrolled transaction in relation to property transferred or services provided. This method is basically applied to concerns engaged in the manufacturing and selling of the product and hence to be applied to manufacturers.

Typical transactions in [...]