Transfer Pricing Service
Related-party transactions need to be defensible.
Transactions between related companies must be priced on arm's length terms — and documented well enough to withstand review.
You have cross-border or related-party transactions.
Documentation is missing or outdated.
You want your pricing position supported.
Transfer Pricing • Documentation • ComplianceTransfer Pricing Service
Transfer pricing services in Malaysia — documentation, TP policies and compliance for related-party transactions.
If your company transacts with related parties — a foreign parent, a sister company, a subsidiary, a director's other business — transfer pricing is no longer something you can afford to ignore.
Under the Income Tax (Transfer Pricing) Rules 2023 and Section 140A of the Income Tax Act 1967, related-party transactions must be conducted at arm's length — meaning at prices that would have applied between independent, unrelated parties. And LHDN expects you to prove it through proper Transfer Pricing Documentation (TPD).
Get it wrong and the consequences are steep: transfer pricing adjustments, surcharges of up to 5% on adjustments, penalties of up to 100%, and a separate penalty of up to RM100,000 for failing to prepare contemporaneous TPD.
At KKHO & Partners, our licensed tax agents prepare full, defensible Transfer Pricing Documentation, conduct benchmarking studies, advise on intercompany pricing structures, and represent clients through transfer pricing audits.
What Is Transfer Pricing?
Transfer pricing refers to the prices charged between related parties for goods, services, intangibles, financing, or other transactions. Common examples include:
- A Malaysian subsidiary paying its foreign parent for management fees, royalties, or technical services
- A Malaysian company selling goods to or buying goods from a related overseas entity
- Intercompany loans and financing arrangements
- Cost-sharing arrangements for shared services across a group
- IP licensing between group entities
- Domestic related-party transactions between Malaysian companies under common control
LHDN's position is simple: these prices must be set as if the parties were unrelated. Documentation must support that position. And the burden of proof is on the taxpayer.
Who Needs Transfer Pricing Documentation?
Under the Transfer Pricing Rules 2023, the requirement to prepare contemporaneous TPD applies to:
- Companies with gross income exceeding RM25 million and related-party transactions exceeding RM15 million, or
- Companies with financial assistance (loans) exceeding RM50 million to or from related parties, or
- Companies engaged in cross-border related-party transactions where TPD is requested by LHDN
For companies below these thresholds, a simplified or "minimum" TPD may still be required — and in any case, the arm's length principle still applies.
In practice: if you have any meaningful related-party transactions, you should have transfer pricing documentation.
Who This Service Is For
Our transfer pricing services are designed for:
- Multinational companies with Malaysian subsidiaries
- Malaysian Sdn Bhd companies with foreign parents, subsidiaries, or related parties
- Group structures with intercompany transactions across multiple entities
- Companies paying or receiving management fees, royalties, or technical fees from related parties
- Companies with intercompany loans or financing arrangements
- Businesses approaching the RM25M / RM15M / RM50M thresholds
- Companies under LHDN transfer pricing audit or query
- Foreign-owned companies entering Malaysia and structuring intercompany agreements
If your auditor has ever asked "do you have transfer pricing documentation?" — and you've hesitated — that's the signal.
What's Included in Our Service
A complete, compliant set of statements prepared to the same standards as our audit work.
Full set of financial statements
Statement of financial position, income statement, changes in equity and notes.
Prepared under MPERS
In accordance with the applicable approved accounting standards.
Directors' report
Directors' report and statement by directors where required.
Aligned with Form C
Your statements agree with your tax computation for LHDN filing.
Submission-ready documents
Prepared for SSM, LHDN, banks and investors.
Audit exemption guidance
Ongoing guidance on your eligibility to remain audit-exempt.
You get documentation that holds up — both to LHDN scrutiny and to your auditor's review.
Why Businesses Choose KKHO for Transfer Pricing
- Licensed tax agents under Section 153. Transfer pricing work is reviewed and signed off by tax agents legally licensed by the Ministry of Finance.
- Real benchmarking, not templates. Many "TPD providers" recycle generic studies. We conduct proper benchmarking using recognised databases — so your documentation reflects your actual business, not someone else's.
- Aligned with substance. Documentation that doesn't match how the business actually operates is the fastest route to a failed audit. We make sure your TPD, your contracts, and your operations tell the same story.
- Cross-border experience. We work with multinational groups and foreign-owned Malaysian entities daily — we understand both sides of the related-party relationship.
- Audit-ready. Our TPD is prepared with one question always in mind: if LHDN audits this tomorrow, does it stand up?
- Coordinated team. Transfer pricing intersects with corporate tax, withholding tax, and accounting. Our integrated team makes sure every piece aligns.
Get Your Transfer Pricing Position Documented Properly
Transfer pricing isn't something to figure out at year-end or wait for LHDN to ask about. Get the documentation done properly now — and the next audit, the next financial year, and the next group transaction become much less stressful.
📞 Get in touch for a confidential consultation — share your group structure and intercompany transactions, and we'll show you exactly how we'd approach the documentation.
Transfer Pricing Service
For groups with related-party and cross-border transactions.
Everything you need to move forward with confidence.
Clear scope, clear process and proper guidance — you will immediately understand what is included and what happens next.
General Information & Review Status
The information on this page is general in nature and does not constitute legal, tax, audit or professional advice. Statutory requirements may change and should be confirmed for your company's specific circumstances with a licensed professional or the relevant authority.
Official sources:
Ready to Get Started with Transfer Pricing Service?
Talk to our team today for a free, no-obligation consultation. We'll review your situation and tell you exactly what's needed — before any commitment.