Master the corporate magic - Transfer Pricing (LTPD)

24th-25th August 2021
Remote Online Training
Fees: RM1,300.00 nett

If you are doing business in Malaysia and having controlled transactions (e.g. buy and sale of goods and providing services) with associated persons (e.g. common directors/major shareholders, partners and relatives) then you need to prepare transfer pricing documentation (TPD).

W.e.f. 1/1/2021, penalty of RM20,000-RM100,000 if you cannot provide transfer pricing documentation (any taxable period) to LHDN upon request within 14 days. However, your business is allowed to prepare Limited TP Documentation (LTPD), if business annual gross income below RM25 million, and total related party transactions not exceeding RM15million per annum; or provision of financial assistance not exceeding RM50 million for non-financial institutions.

OBJECTIVE:

The Malaysian Transfer Pricing Guidelines 2012 prescribes the following financial thresholds for preparation of a comprehensive set of transfer pricing documentation, i.e. Full Transfer Pricing Documentation: This training is to assist the business to prepare the LTPD by themselves in order to comply with tax authorities requirements.

HOW WILL YOU BENEFIT:

At the end of this training session, participants will learn to:

  • Know the duty to prepare Transfer Pricing Documentation
  • Understand transfer pricing principles and rules, e.g. Arm’s

Length Principle

  • Update on the latest transfer pricing guide
  • Prepare organization and ownership structure
  • Analyse the associated persons relationship
  • Identified controlled transactions
  • Select the appropriate transfer pricing method via group discussion
  • Identified Function, assets and risks (FAR) of the business
  • Prepare pricing policy using template
  • Prepare LTPD by reference to toolkits
  • Analyse matters pertaining to intragroup services

METHODOLOGY

Lecture, toolkits, power point presentation, discussions, questions & answers sessions.

Course Outline

Module 1: Duty to prepare Transfer Pricing Documentation
  • Transfer pricing principles and rules
  • Transfer pricing guides
  • Timeline to submit LTPD
Module 2: Business organization chart
  • Ownership structure
  • Associated persons relationship
  • Stakeholders involvement
  • Management description of the management structure
Module 3: Who are the associated persons
  • Identified the associated persons who are dealing the business
  • Determining their relationship
  • Gathering of controlled transactions
  • Practical exercise
Module 4: The types of common controlled transactions
  • Sales or purchase of raw materials
  • Services, rent, intangible assets and management fees
  • Interest or guarantee fees
Module 5: Controlled transactions details
  • Description of the controlled transactions (e.g. procurement of manufacturing products, purchase of trading goods, provision of services)
  • Details in contracts, agreements and purchase orders for controlled transactions
  • Budget and forecast for controlled transactions
  • Scope of transactions, timing and frequency
Module 6: Functional, Assets and Risk Analysis (FAR)
  • Introduction of FAR
  • Practical exercise to determine business’s FAR
Module 7: Transfer Pricing Methodologies
  • Understand the TP pricing methods
  • Choices available
  • Which TP pricing method is suitable for your business?
  • Group discussion
Module 8: Pricing policies
  • What is the formula adopted to decide on selling price?
  • Find out the business anticipated profit margin/mark up for its products/services? What is the rationale apart from directors’ discretion?
  • Practical exercise
Module 9: How prescriptive should the transfer pricing policy be?
  • Ready supporting documentation to support the setting of product’s pricing
  • Preparation of written procedure on how to select most appropriate transfer pricing method with regard to the category of transaction
  • How frequent is the review of the product pricing been conducted

Module 10: Matters pertaining to intragroup services

  • Analysis of document/information relating to services performed by the respective associated persons/group members.
  • Explain how the activities are carried out
  • How to determine arm’s length price for intragroup services?
  • Direct charge and indirect charge method
  • Other factors to be considered, e.g. proof of provision of intragroup services and the competency in providing such service.

Trainer Profile

Li Jiajing Lee Jia Jin, HRD Corp (formerly HRDF) certified trainer, graduated from the University of Raman with a Bachelor of Commerce (Honours Degree) in Accounting. Now he is the managing partner of KAC Advisory Services PLT (KACPLT). After graduation, he worked in accounting-related work at KAC Advisory Services Sdn Bhd (KACSB). In 2015, when the government implemented GST (Goods and Services Tax), he participated in a team composed of KACSB executive directors to provide consulting work related to the implementation of GST for companies in different fields, such as: manufacturing, service industry, multinational companies, Listed companies and state-owned companies. He also participated in consulting work related to Sales Tax and Service Tax (SST). He successfully guided many people without an accounting background to prepare accounts that comply with accounting standards for management reports and financial reports. He believes that selflessly sharing his accumulated practical knowledge and experience is the best way to help others understand and use them in daily work. In addition, he is also good at operating ABSS (formerly MYOB) accounting software.

He has conducted various GST and accounting-related trainings to help participants learn in a relaxed and easy-to-understand environment, and share their own experience and be wary of those who participate in the training to prevent them from falling into unnecessary traps. Recently, he has been actively involved in transfer pricing (Transfer Pricing) and has trained more than 10 days in a workshop on how to prepare transfer pricing documents (LTPD), allowing many companies to prepare their own transfer pricing documents.

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