Source: Australian Tax Forum Journal Article
Published Date: 1 Sep 2013
With the growing number of MNEs investing in the Asia-Pacific region, transfer pricing has become the most challenging tax issue for the companies and tax authorities in this region. This study examines the factors that could potentially trigger a transfer pricing audit of MNEs operating in Malaysia. Data collected from the tax authority shows that MNEs with low net profit margin were prone to audit. A disproportionate focus of audit was on larger MNEs. MNEs audited include manufacturers, distributors/retailers, or those in the service industry and involved primarily in tangible goods and intra-group services. The results suggest that the Malaysian tax authority is becoming more vigilant in transfer pricing audit, and with more guidance from the United Nations and OECD to combat international transfer pricing tactics, its audit strategy and processes are bound to grow in scale, scope and sophistication.
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