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Governments design transfer pricing guidelines with large multinational corporations in mind, and may neglect to simplify them for small & medium sized enterprises (SMEs). With this issue clearly in mind, what is the strategy and approach to take with practical transfer pricing advice? Transfer pricing is
complex because variations in business circumstances dictate transfer pricing methods.

SMEs need a specified guide to start transfer pricing documentation, so we turn our attention to 3 key steps to make sure they understand transfer pricing and avoid misapplied comparable methods. First is to communicate with business owners on their business model so we understand the business processes with uncontrolled transactions. Then we address the comparable uncontrolled transaction method and select the transfer pricing method as the basic data that would apply in each instance. Finally, we examine the range of arm’s length principles and undertake contemporaneous documentation to avoid transfer pricing penalties.

  • Comprehend the strategy available to prepare transfer pricing documentation for trading and manufacturing sectors
  • Understand the business process and analyse its function, assets, and risk, and to benchmark against competitors and the industry
  • Learn the 3 key steps in preparing a transfer pricing document for SMEs, applying

Module 1: Overview of the Practical Aspects of Transfer Pricing

  • Introduction to controlled transaction and relationship of parties
  • “Head in the Sand” approach
  • Comprehensive Analysis approach


Module 2: Communicating with Business Units
on Their Functions, Assets and Risks

  • To undertake FAR analysis, we must transcend and not challenge the requirement of transfer pricing
  • Elicit business process with business model canvas


Module 3: Understanding Comparability Analysis from the Standpoint of Transfer Pricing Methodologies

  • The basics of transfer pricing method
  • Comparability of data and assumptions


Module 4: Applying Arm’s Length Principle in Transfer Pricing Documentation

  • Claiming the Arm’s length range
  • Transfer pricing as a decisionmaking process
  • CEOs and CFOs
  • Managers
  • Auditors
  • Finance Employees
  • Tax Professionals
  • Firms that want to provide additional TP services

Get in touch

+6012-215 9885
B-­04­-43, Blok B, Pusat Perdagangan Ekoflora, Jalan Ekoflora 7/1, Taman Ekoflora, 81100 Johor Bahru, Johor, Malaysia.

29-1, Jalan 2a/27a, Seksyen 1 Wangsa Maju, 53300 Kuala Lumpur, Malaysia.

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