Treasure Advisory Sdn Bhd

Most Malaysian SMEs assume transfer pricing doesn’t apply to them—until an IRBM audit proves otherwise.

From informal pricing decisions to undocumented intra-group services, these small oversights can snowball into hefty penalties, adjustments, and months of scrutiny.

If your SME has any cross-border related-party transactions, TP isn’t optional—it’s a compliance mandate.

Curious why so many SMEs overlook it and what the hidden risks really are?
Read the full breakdown on the Treasure Advisory blog: Why Malaysian SMEs Ignore Transfer Pricing—Until It’s Too Late

👉 Link to the post https://tinyurl.com/why-sme-ignore-tp

Why Malaysian SMEs Ignore Transfer Pricing—Until It’s Too Late Transfer pricing compliance isn't just for MNCs. Malaysian SMEs face LHDN audits, penalties, and tax adjustments for non-compliance. Learn why documentation matters, common mistakes, and how to

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Many Malaysian businesses pay for intra-group shared service but not all of them qualify as deductible expenses in the eyes of the IRBM.

💡So what’s the difference?
Only services that have real commercial value and economic substance are chargeable. These are services that genuinely support business operations and meet both the benefit test and the independent party willing to pay test include IT support, HR functions, logistics coordination, centralised marketing and other operational support services.

Companies often fail to recognise that there are some services not chargeable such as shareholder activities, passive association, duplicate activities and on call services.
These are costs typically incurred for the benefit of the parent company or group management rather the and the subsidiaries. If these charges are billed to your subsidiaries, IRBM may disallow the deduction during tax audit.

This distinction is one of the most common reasons for transfer pricing adjustments in Malaysia.

Explore our services, workshops, and blogs on Transfer Pricing. Visit us at treasureadvisory.com.

Family-owned businesses are the backbone of Malaysia’s economy—but they’re also among the most vulnerable when it comes to transfer pricing (TP) pitfalls.

Here are 3 costly mistakes many make without realising:

1️⃣ Treating related-party transactions (RPT) casually
Handshake deals, verbal agreements, and “family understanding” don’t work with the IRBM. Every RPT needs clear pricing logic and documentation.

2️⃣ Undercharging or overcharging group entities
Favouring one entity over another—often to “help with cash flow”—leads to non–arm’s length pricing. This is one of the quickest ways to trigger TP scrutiny.

3️⃣ Ignoring TP documentation because they’re ‘not an MNC’
If you have related party transactions, irrespective local or cross-border transactions, you MUST comply with arm's length principle. Family-owned doesn’t mean exempt, and penalties can be steep.

💡 A strong TP policy protects your business, your family legacy, and your tax position.

For expert guidance, more on transfer pricing, and TP documentation support, visit Treasure Advisory.

📢 IRBM’s Latest Audit Focus: Stay Compliant and Protect Your Business

The Inland Revenue Board of Malaysia (IRBM) has intensified its focus on transfer pricing and controlled transactions, making compliance more important than ever. From stricter audit protocols to penalties and surcharges, Malaysian businesses need to understand the Transfer Pricing Tax Audit Framework 2025, documentation requirements, and voluntary disclosure options under the Income Tax Act 1967 and Transfer Pricing Guidelines 2023 📄.

Our latest blog breaks down what your company needs to know to stay audit-ready, minimize risk, and maintain compliance.

For expert guidance and practical support on transfer pricing compliance, documentation, and audit defense, trust Treasure Advisory
— helping Malaysian businesses navigate complex tax regulations with confidence.

🔗 Read the full article here:https://tinyurl.com/tp-audit-focus

Understanding Controlled Transactions: How Malaysian Businesses Stay Compliant with IRBM ✅

Controlled transactions—business dealings between related parties—are under increasing scrutiny by the Inland Revenue Board of Malaysia (IRBM). From intercompany sales and services to financial arrangements and cost-sharing, Malaysian companies must ensure all related-party transactions comply with the arm’s length principle, as mandated under the Income Tax Act 1967 and Transfer Pricing Guidelines.

Our latest blog breaks down the types of controlled transactions, compliance requirements, and best practices to help your business avoid penalties, optimize operations, and maintain transparency.

🔗 Read the full article here: https://tinyurl.com/controlled-transactions

Understanding Controlled Transactions – Insights from Malaysia’s Transfer Pricing Regulations Gain key insights into Malaysia's Transfer Pricing rules for controlled transactions. Stay compliant & optimize your intercompany pricing strategies.

📊 Understanding Transfer Pricing in Malaysia: Are You Audit-Ready?

With the IRBM’s heightened focus on transfer pricing and controlled transactions, Malaysian businesses must stay compliant under the Income Tax Act 1967 and Transfer Pricing Guidelines 2023. From intercompany sales and services to intangible asset licensing and financial arrangements, proper documentation and arm’s length pricing are key to avoiding penalties.
November is the perfect time to review your transfer pricing policies and ensure your documentation is up-to-date before year-end audits.

For expert guidance, benchmarking studies, and audit support, visit treasureadvisory.com

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💡 Transfer Pricing Best Practices: Stay Compliant and Confident

Malaysian companies with intercompany transactions — whether domestic or cross-border — need robust transfer pricing strategies to stay compliant under IRBM regulations. Key steps include:
✅ Early identification of related-party transactions
✅ Maintaining contemporaneous Transfer Pricing Documentation (TPD)
✅ Annual benchmarking and outcome testing
✅ Engaging professional advisors for complex arrangements

Treasure Advisory helps businesses navigate these requirements, minimize audit risk, and ensure compliance with the Income Tax Act 1967 and Transfer Pricing Guidelines.

Learn more, visit us at treasureadvisory.com

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💡 Avoid costly mistakes in Malaysian transfer pricing! Conducting a proper functional analysis is your key to identifying comparables that leads to right pricing strategy and staying audit-ready.

Did you know? A well-prepared functional analysis doesn't just help determine arm's length pricing-it can also protect your business from potential TP tax adjustment in Malaysia.

🔍 Unlock the power of Functional Analysis for Malaysian transfer pricing compliance!

Functional Analysis is the backbone of transfer pricing compliance in Malaysia. By analyzing the functions, assets, and risks of each entity, Malaysian businesses can ensure arm’s length pricing, defend intercompany transactions, and reduce the risk of penalties from the IRBM.

Our latest blog breaks down why Functional Analysis matters, how it supports your CTPD, guides your transfer pricing methodology, and protects your business from LHDN adjustments.

Stay audit-ready and compliant with Malaysia’s latest MTPG 2024 and Transfer Pricing Rules 2023.

Read the full guide 👉 https://tinyurl.com/Tp-functional-analysis

🚨 Avoid costly tax adjustments! Discover the key steps every Malaysian business should take before a transfer pricing audit. Transfer pricing audits in Malaysia are becoming more stringent under the IRBM’s 2023 Transfer Pricing Rules and MTPG 2024. Ensuring your CTPD, RPTs, functional analysis, benchmarking, and intercompany agreements are accurate and up-to-date is critical to staying compliant.

✅Our latest blog provides a practical 10-point checklist to help your business:
✅Prepare contemporaneous transfer pricing documentation (CTPD)
✅Review related party transactions (RPTs)
✅Conduct functional and benchmarking analyses
✅ Substantiate intragroup services & intangibles
✅ Prepare for IRBM queries and audits
✅ Stay audit-ready, mitigate risks, and ensure compliance with Malaysia’s latest transfer pricing regulations.

Read the full guide here 👉 https://tinyurl.com/10-point-tp-checklist