[01] COURSE INTRODUCTION 

Transfer pricing strategies play an important role in key business performance areas such as optimizing tax efficiency, reducing legal exposure/risks and increasing cash flow. Gain an under- standing of IRB’s new section 140A and how it impacts you. 

A majority of the world’s cross-border transactions now occur through related entities, bringing with it various tax and business concerns. Hence, transfer pricing strategies play an important role today in key business performance areas such as optimizing tax efficiency, reducing legal exposure/risks and increasing cash flow. 

In Budget 2009, IRB introduced the new section 140A in the Income Tax Act, 1967 on “Transfer Pricing”. This new section in the legislation has major tax implications on related party trans- actions in Malaysia. In addition, new transfer pricing rules and guidelines have been issued to supplement the new Section 140A. 

This program will show you the groundwork that needs to be put in place in order to comply with the IRB’s guidelines, and to stay within the law. 

[02] COURSE OBJECTIVES 

• Discuss key issues related to Transfer Pricing and record keeping that meet IRB’s requirements 

• Identify key technical, issues and factors in supporting the arm’s length nature of related party transactions 

• Keep abreast with the latest updates on legislation and guidelines issued by IRB on Transfer Pricing in Malaysia 

[03] WHO SHOULD ATTEND 

Directors, Financial Controllers, Finance Managers, Accountants, Tax Consultants, Tax Practitioners/Advisors, Company Secretaries. 

[04] METHODOLOGY 

Lectures, PowerPoint presentations, discussions and case studies. 

[05] DATE/ TIME/ FEE
Date:     20 May 2024 (Mon)

Time:     9.00am – 5.00pm
Venue:   Empire Hotel, Subang Jaya

FEE:   
   - Early Bird Offer (before 2 May 2024)     –      RM 800
   - Special Offer (before 16 May 2024)     –      RM 840
   - Normal Fee      –      RM 880
 
    >> Fee includes Course Notes, Meals, Certificate of Completion and 8% Service Tax.
 
** OFFER **
   - 10% Cashback for SST2u Learner Card+ (SLC+) members. T&Cs applied
 

[06] COURSE OUTLINE 

Module 1 - New Transfer Pricing (TP) Rules 2012 and TP Guidelines 2012 

• Scope of TP Rules and Guidelines
• Meaning of control and associated
• Meaning of arm’s length principle
• Determination of arm’s length price
• Factors determining comparability
• Different TP methodologies in arriving at arms’ length price
• TP adjustment by DGIR
• Compensating adjustment 

• Intragroup services
• Cost contribution arrangement
• Intangible properties
• Intragroup Financing (Loan)
• Interest on financial assistance
• Retention of records
• Contemporaneous TP documentation
• Penalty
• New form on Cross Border Transactions by IRB (Form MNE) 

Module 2 - Advanced Pricing Arrangement (APA) Rules 2012 and APA Guidelines 2012 

• Scope of APA Rules and Guidelines 

• APA process
• Withdrawal of APA
• Effect of APA 

• Request for rollback
• Filing of APA compliance report 

• Revision/Cancellation/Revocation/Renewal of APA 

• Form APA1 and APA2 

Q&A Session 

End of Training 

[07] TRAINER PROFILE 

HARI RAMULU M. 

HRDF Certified Trainer 

Hari Ramulu Munusamy is a Business Financial Consultant cum Lecturer, with wide experience in public practice and in financial management & public sector accounting, auditing and taxation educational process, having been in the profession and industry since October 1976. 

He started his career with Messrs F. H. Eiles & Co., a firm of Chartered Accountants in London as an Audit Assistant in October 1976. Subsequently, he contin- ued his career as an Audit Supervisor with Messrs Coopers & Lybrand (now known as Pricewaterhouse- Coopers), Kuantan in May 1984. In January 1986 he joined Messrs Senthe & Co (a firm of Chartered Accountants in private practice in Petaling Jaya), as an Audit Manager, till December 2006. Over the years, he gained knowledge, experience, skills and expertise in accounting, auditing and taxation servic- es including tax investigation, forensic accounting and company floatation. 

He had conducted seminars and courses in financial accounting, internal auditing, external auditing, and taxation to practitioners and general public. 

Professionally, he is a Fellow member of the Associa- tion of Chartered Certified Accountants of UK, a Chartered Accountant of the Malaysian Institute of Accountants, an Associate member of the Malaysian Institute of Taxation, a Chartered member of the Institute of Internal Auditors of Malaysia (affiliate of USA), and an Associate member of the Certified Fraud Examiners of USA. His academic qualifications are Diploma in Accountancy (Newcastle-Upon-Tyne, England), and Master of Business Administration (Accounting) from University of Newcastle, USA. 

Credentials: 

• Master in Business Administration (Accounting), University of Newcastle, USA 

• Fellow Member of the Association of Chartered Certified Accountants, UK 

• Chartered Member of the Malaysian Institute of Accountants, Malaysia 

• Associate Member of the Chartered Institute of Tax, Malaysia 

• Chartered Member of the Institute of Internal Auditors, Malaysia 

• Associate Member of the Association of Certified Fraud Examiners, USA 

[08] ENQUIRY & REGISTRATION 
Enquiry: yes@sst2u.com
Contact:
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