Abstract
Inland
Revenue Board of Malaysia has issued a new Transfer
Pricing Guidelines (N1) and Advance
Pricing Arrangement Guidelines (N2). While the Rules cover the application
of Sections 140A (N3)
and 138C (N4) of the
Income Tax Act 1967, the Guidelines are intended to explain administrative
aspects of the Rules.
As per
title, we are mainly focus on the item N1 and N3 (Transfer Pricing) in this
topic discussion which the guideline been published by 10th August 2012.
Here provide you a summary of content and further discussion from the summary by click in to the link:-
(Note: Kindly advice if there is any omission or mistake noted. Your feedback is highly appreciated. Thanks very much!!)
Please come to my skeleton at: http://msiataxjunior.blogspot.com/2012/09/irbm-transfer-pricing-guidelines-2012.html
**N1 :For Transfer Pricing Guidelines, please refer to:
**N2 :For Advance Pricing Arrangement Guidelines, please refer to:-
**N3 :For 140A. Power to substitute the price and disallowance of interest on certain transaction, kindly refer to:
**N4 : For 138C. Advance Pricing Arrangement, please refer to:
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OECD Transfer Pricing
Discussion
Beyond the exact IRBM Transfer Pricing
Guideline 2012, I may also recommended you can refer to the Organization for Economic Co-operation and
Development (OECD) discussion on
International Transfer Pricing which considered the main and ultimate transfer
pricing research body.
OECD official website: http://www.oecd.org/ctp/transferpricing/
Other relevant website:
Transfer Pricing Introduction:-
Transfer Pricing Country Profiles:-
OECD
ARTICLES OF THE MODEL CONVENTION
MULTI-COUNTRY ANALYSIS OF EXISTING
TRANSFER PRICING SIMPLIFICATION MEASURES
OECD
Transfer Pricing Guideline for Multinational Enterprises and Tax Administrative
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