Tax: Transfer Pricing & Investigations

Transfer Pricing covers all aspects of inter-company pricing arrangements for goods and services.

Such inter-company transactions across borders are growing rapidly and are becoming much more complex. Compliance with the differing requirements of multiple overlapping tax jurisdictions is a complicated and time-consuming task. At the same time, tax authorities both local and regional are imposing stricter penalties, new documentation requirements, increased information exchange and increased audit/inspection activity. In Malaysia, heavier compliance obligations mean companies need to keep up with Transfer Pricing (TP) developments.

Do you:

  • need to better understand regional TP Tax Audits?
  • want to plan your taxes through more efficient TP techniques like incentives in using Malaysia as a business hub or realignment of group profits?
  • require a more in-depth understanding of TP audits components from common irregularities to documentation requirement?
  • need to respond to a tax authority transfer pricing audit / enquiry?
  • want reasonable assurance that your internal controls over transfer pricing are sufficient?
  • want to know what are the "best practices" for managing your worldwide transfer pricing policies and procedures?

How we can help

Whatever your Transfer Pricing needs, our dedicated Transfer Pricing professionals are ready to work with you to create a set of transfer pricing products to assist you in achieving your strategic global business objectives.


As tax investigations and field audits by the Inland Revenue Board become more regular and systematic, companies will need an unusual blend of skill and experience to deal with such reviews effectively. Our tax investigation service provides support to the company during the course of an investigation. This could include:
  • Advising on interpretation and application of highly complex and sometimes ambiguous rules and regulations prescribed in the Revenue Code;
  • Coordinating with the Revenue Officer and providing necessary documents and information;
  • Defending transactions under attack with effective strategies;
  • Negotiating exceptions to tax compliance to minimise tax liabilities;
  • Reducing burden of document preparation; and
  • Shortening the investigation period through satisfactory resolution of issues.
If not properly dealt with, an investigation or field audit could result in unexpected and excessive liabilities, not to mention a diversion of company's resources of time and energy. So why not plan for this and act now for a favourable outcome? PwC's tax investigations services may involve:
  • Managing tax risks
  • Risk reviewing specific areas of tax such as entertainment costs, benefits or VAT
  • Assisting with voluntary disclosures
  • Defending all types of tax enquiries (including special compliance office investigations)
  • Advising on information powers, interest and penalties
  • Tax appeals and tribunals