Malaysia Transfer Pricing 2018: Complete & Practical Preparation For Transfer Pricing Audit

Get yourself ready to face the Malaysia Transfer Pricing 2018 with Confidence!

With effect from 1.1.2018, the FAILURE to have TRANSFER PRICING DOCUMENTATION will be regarded as an Incorrect Return by Malaysia Inland Revenue Board (IRB) and penalised 100% of Tax Undercharged.

Related parties’ transactions, be it Sales of Goods, Provision of Management Services, Payment for Marketing Services, Intercompany Loan and Advances, Cost Allocation and Recovery have to be reflected at FAIR PRICE, which denotes Market Value.

It is a General Rule that the basis of charging must be supported by an agreement referencing to the methodology used, time spent, nature and complexity of the transaction.

Mandatory to Prepare Transfer Pricing Documentation

The Malaysia Income Tax Act 1967 coupled with the Income Tax (Transfer Pricing) Rules 2012 and Transfer Pricing Guidelines 2012 imposed a mandatory requirement on the preparation of CONTEMPORANEOUS TRANSFER PRICING Documentation (TP Documentation) PRIOR TO SUBMISSION OF TAX RETURN.

Practical Approach to Preparation of Transfer Pricing Documentation

Prepare TP Documentation Confidently! Practical Guide will be provided to identify the appropriate commercial basis to REFLECT ARM'S LENGTH PRICE.
Know the required elements needed in SUPPORT OF THE RELATED PARTIES' TRANSACTIONS VIA AGREEMENT or more.

The vital aim of this Malaysia Transfer Pricing 2018 seminar is to provide Companies, Tax, Legal, Director and Accounting Professionals what are the Transfer Pricing Audit’s foreseeable CHALLENGES and the CONCERNS needed to be addressed. Be well equipped to prepare TP Documentation personally, as well as able to critically review TP Documentation prepared by others.

This 2 days workshop presented is based on Case Study approach where it will present the expected Challenges and provide Solutions to contentious issues faced in Transfer Pricing Audit.

Malaysia Transfer Pricing 2018. Let Dr Choong Kwai Fatt empower You with the Complete & Practical Preparation for Transfer Pricing Audit!


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What is this programme about?

Specially for those who want to learn the Complete and Practical Solutions for Transfer Pricing Audit

Dr Choong will present the Essential Concepts and Methodologies evolving within Malaysia  Transfer Pricing. Based on Real Scenarios or Case Studies approach to illustrate its practical application what are the Practical Preparation needed.

Dr Choong will present various Pragmatic Solutions and approaches during this 2 Days Malaysia Transfer Pricing 2018 seminar.

This seminar will better illustrate the challenges and expedite the preparation for Transfer Pricing Documentation. The case studies and case precedent approaches are the
first of its kind in understanding not only how to face, but also how to deal with them in the preparation for Transfer Pricing.

The scope and contents for this 2 Days Malaysia Transfer Pricing 2018 includes but not limited to the following:


1. The Distinction between Transfer Pricing and Tax Evasion – Be Clear on the thin line which Demarcates the Legal from the Illegal Practices.

2. Computation of Arm’s Length Price – The Crucial Foundation to REALLY Understand the Mechanism of Transfer Pricing.

3. Clear Understanding of Transfer Pricing Methodologies – Guide to Selecting the RIGHT Methodology for Which type of Transaction:

3.1. Comparable Uncontrolled Price Method

3.2. Resale Price Method

3.3. Cost Plus Method

3.4. Profit Split Method

3.5. Transactional Net Margin Method.

4. Comparable Adjustment in arriving at Arm’s Length Price NO Two Companies are the SAME.

Comparable Adjustment is Necessary, the Question is What Are the RIGHT Adjustments and HOW to Support and Justify?

5. Intercompany Services and its Appropriate Pricing Methodology – How to Present, and What are the RIGHT DOCUMENTATION that Must Be in place to AVOID Being Challenged by Tax Authority.


6. Transfer Pricing Rules Applicable to TP Documentation – In Compliance to the TP Guidelines 2012. 

What does Tax Authority REALLY Expect from Taxpayer?

7. Transfer Pricing Audit and Assessment – Know What Are the Foreseeable Challenges you will face in TP Audit and the Latest Strategies to Overcome them?

8. Appeal on TP Penalties Focus on the Winning Points and Strategies to implement.

9. Intercompany Loan Transactions – What is the RIGHT Interest Rate to be Used and the MUST Have Component of Loan Agreement?

10. LATEST Withholding Tax Concerns and GST Implication on Related Parties’ Imported Services – Understand How It Works and to What Extend would this Applies?

11. Deep Look into Important TP Tax Cases and their Decisions – The PRICELESS Mistakes and Lessons YOU Must Be Aware Of.

12. Very Hands-On Guide on Exactly HOW to Prepare RIGHT TP Documentations in Compliance to TP Guidelines 2012.

13. PRACTICAL Issues Encountered from Transfer Pricing – This is a Must-Know for all.

14. and more…   


Join Malaysia Transfer Pricing 2018 NOW to learn the Complete and Practical Preparation For Transfer Pricing Audit (TP Audit).

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Who is it for?

Created for the Business, Financial Decision Makers and Advisors

Shareholders and Directors

(Personnel involved in Managing the Company)
Shareholders and Directors are exposed to personal risk of travel restriction, personal liability to pay for “tax undercharged” and company bankruptcy. Therefore Shareholders and Directors must have personal understanding of what are the risk they are facing and ensure the right safeguard is in place.
(applicable to all industry).



Business and Financial Decision Makers

(CEO, CFO, General Manager and Financial Controller)
To be ready for TRANSFER PRICING in 2018 major changes is needed and the right documentation must be in place. The Decision Makers must be well advised and comprehend the significance and able to plant the right trasnfer pricing Documentation and approach.

Company Secretary, Auditors, and Tax Agents

The Advisor needs to gear up and patch up your dose of LATEST TRANSFER PRICING DOCUMENTATION AND TP AUDIT KNOW HOW and NEW Action Plan.

Company Secretary, Tax Agents and Auditors has a substantial role to play in advising business owner how to preempt and where their opinion is highly valued to assess on adequacy of RIGHT TRANSFER PRICING Audit Documentation.


Legal Professionals, Contract Manager, Corporate Lawyer, Business Consultant, Business Advisor, In-House Lawyers

The one who will give advise on Adequacy of Evidence, be it in Business Transaction, M&A issues and other Corporate Legal Issues. It is the right time to understand and be aware of MALAYSIA’s LATEST TRANSFER PRICING AUDIT PREPARATION.
Your legal advice on the right documentation trail will significantly impact taxpayer’s probability in wining in tax audit dispute with the authority.

Accountants, Financial Controller, Senior Executives

Applying a new MFRS and new GST are tough enough, plus a whole New Companies Act which is bringing Malaysian Business structure change and cut across all industries in your accounting work. NOW there is another wave of change in TRANSFER PRICING AUDIT that you MUST BE READY FOR.

With THE SUBSTANTIAL CHANGES needed in PREPARATION FOR TRANSFER PRICING AUDIT, the Record Keeping and recording of Historical Transaction has a NEW Role to play, it is paramount important for you to understand all the LATEST ins and outs of TRANSFER PRICING AUDIT.

How it will affect your documentation from now onward and all the compliance requirements and thresholds table involved. There are ample work to PATCH UP on the missing documentation since the IMPACT OF LACKING IN RIGHT DOCUMENTATION has SUBSTANTIAL PRICE TO PAY.


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About the Speaker

Get to know more about this wonderful speaker

What people says about him :

“The 2 Hours Q&A is VERY IMPRESSIVE! He is so hands-on that he can answer any questions, no matter how complex, in a split seconds. Among the peers, we nicknamed him the “human answer machine

“He was my lecturer for ACCA paper, now a tax lawyer, after so many years he is still humorous, able to make complex and boring taxation into a humorous and fun event. Definitely coming back for more.”

DR CHOONG KWAI FATT is the expert in tax planning for companies and individuals. He is appointed by the Ministry of Finance as one of the panel members to review tax reforms in Malaysia.

He has conducted and published extensive researches on tax way back since 2006. Dr Choong being an avid researcher, he has also studied Taxation System from various countries. Many of his works are quoted in Tax Cases.

He has more than 24 years’ experience of providing consultancy services to listed companies, audit firms and the Government. Dr Choong is a highly sought Taxation speaker. He is highly qualified with both professional Accounting Qualification and Legal Qualification. With chartered accountancy from 6 professional bodies and called to bar as an Advocate and Solicitor in Malaysia. Also an avid researcher equipped with a PhD in Taxation.

He has won various awards for excellent in tax research and published GST & Taxation Articles in reputable journals in and outside Malaysia. His research works have been quoted in many tax cases and have influenced the formulation of tax policy in Malaysia.

He is known by attendee of his seminar as a man with heart of gold. He is passionate about helping the tax professionals, accountants, senior executive, lawyers and business owners to enhance in taxation skills, knowledge and wealth through mitigating of financial risks and taxation implementation. Having more than 20 years of experience in public speaking, participants love him for his passion in taxation and ability to make complex tax concept understandable by different walks of life.

He is also widely known for his ability to formulate the “unthinkable” strategies and clearly thought of implementation plan. He is constantly sought by many listed companies as well as high net worth individuals and SME for his practical and impressive strategies as to tax planning, corporate restructuring and of course, his foresight into the potential Transfer Pricing concerns.

He is the expert of experts in terms of Tax Planning, corporate restructuring and transfer pricing, where he provides advice and personally trained corporate accountants, professional firms, company secretary and legal advisors on corporate restructuring, transfer pricing, Income Tax, Tax Audit, RPGT and GST implementation. Get ready to take good notes when you attend this 2 Days Malaysia Transfer Pricing 2018 seminar.



Dr Choong Kwai Fatt

Tax Consultant, Advocate and Solicitor (High Court of Malaya)
B.Acc(Hons)(Malaya),LL.B(Hons)(London), CLP, MCL(IIUM),PhD(IIUM),
FCCA(UK), CPA(M), CA(M), ACA(ICAEW), CA(Aust.),CPA(Aust.), CGA(Can), FCCS.



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Program Timeline: 5 & 6 July 2018

The estimated timeline to discover Transfer Pricing 2018

Day One: 5th July 2018, Thursday (The Gardens, Mid Valley City)

9.00 AM

The Distinction between Transfer Pricing and Tax Evasion – Be Clear on the thin line which Demarcates the Legal from the Illegal Practices.

Computation of Arm’s Length Price – The Crucial Foundation to REALLY Understand the Mechanism of Transfer Pricing.

10.30 AM

Clear Understanding of Transfer Pricing Methodologies - Guide to Selecting the RIGHT Methodology for Which type of Transaction:

Comparable Uncontrolled Price Method

Resale Price Method

Cost Plus Method

Profit Split Method

Transactional Net Margin Method

1.30 PM

Comparable Adjustment in arriving at Arm’s Length Price NO Two Companies are the SAME

Comparable Adjustment is Necessary, the Question is What Are the RIGHT Adjustments and HOW to Support and Justify?

3.15 PM

Intercompany Services and its Appropriate Pricing Methodology –

How to Present, and What are the RIGHT DOCUMENTATION that Must Be in place to AVOID Being Challenged by Tax Authority.

5.00 PMQ & A Session
7.00 PMEnd of live event

Day Two: 6th July 2018, Friday (The Gardens, Mid Valley City)

9.00 AM

Transfer Pricing Rules Applicable to TP Documentation – In Compliance to the TP Guidelines 2012.

What does Tax Authority REALLY Expect from Taxpayer?

Transfer Pricing Audit and Assessment – Know What Are the Foreseeable Challenges you will face in TP Audit and the Latest Strategies to Overcome them?

10.30 AM

Appeal on TP Penalties Focus on the Winning Points and Strategies to implement.

Intercompany Loan Transactions – What is the RIGHT Interest Rate to be Used and the MUST Have Component of Loan Agreement?

1.30 PM

LATEST Withholding Tax Concerns and GST Implication on Related Parties’ Imported Services – Understand How It Works and to What Extend would this Applies?

Deep Look into Important TP Tax Cases and their Decisions – The PRICELESS Mistakes and Lessons YOU Must Be Aware Of.

3.15 PM

Very Hands-On Guide on Exactly HOW to Prepare RIGHT TP Documentations in Compliance to TP Guidelines 2012.

PRACTICAL Issues Encountered from Transfer Pricing – This is a Must-Know for all.

5.00 PMQ & A Session
7.00 PMEnd of live event

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3 Ways to Register

There are 3 ways you can register. Choose any of the following.

1. Register Online (Most Popular Option!)

You will receive an email containing the Tax Invoice after submitting the Online Form.
This is the Fastest and Most Convenient way to register yourself for this exciting upcoming event.
Fill up the Online Form and Click Submit button, you shall receive an email for the Tax Invoice.
Follow the Payment Method on the Tax Invoice to make payment.
If you are making payment while filling up this Online Registration form, you can upload your payment transaction slip too.

Click here to Register Online

2. Download the Physical Form (For Hardcopy Registration)

This is the Best Option for you to get approval from your management!
Simply click below to download the Form and fill them.
Thereafter, scan and email your form to us.
We will process the form and email you the Tax Invoice.
Follow the Payment Method on the Tax Invoice to make payment.

Click here for Physical Registration Form

3. Email Us (For Multi-Company Registration)

For those who are in GROUP REGISTRATION and require MORE THAN 1 Tax Invoice. You can email to us via with the following information:
Participant's Name, Gender, Valid Contact Number, Designation, Email.
Company's Particulars and the person to be liased in relation to payment.
If you require Tax Invoice for different Companies, kindly indicate in the email for example:
Participant 1 under Company A's Tax Invoice;
Participant 2 and Participant 3 are under Company B's Tax Invoice, etc.
We will do the necessary and email you the Tax Invoice.
Follow the Payment Method on the Tax Invoice to make payment.

Click here to Email Us

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Price/ Register Online

Choose the right category based on Number of Participants

RM2,900+ (for two days) Normal Price 1- 2 Pax

Register for this event at Normal Price.
This rate applicable to registration after 8th June 2018.
Fee is subject to 0% GST.

Register of 1-2 pax Online

RM2,700+ (for two days) Group of 3 - 4 Pax

Register three or more participants to enjoy additional RM 200 off =
(RM 2,900 - RM 200 Group Registration Discount = RM 2,700+ per pax for two days)
Fee is subject to 0% GST.
Seats are limited and subject to availability.

Register Group of 3 - 4 pax Online

RM2,500+ (for two days) Group of 5 Pax and more

Register five or more participants to enjoy additional RM 400 off =
(RM 2,900 - RM 400 Group Registration Discount = RM 2,500+ per pax for two days)
Fee is subject to 0% GST.
Seats are limited and subject to availability.

Register Group of 5 or more Pax Online

Meet Dr Choong Kwai Fatt live. He is known for his ability to simplify complicated tax law, into reader friendly and easily digest pieces.

He will reveal the Practical and Complete Preparation for Transfer Pricing Audit based on latest analysis. Real and Valuable Lessons can be learnt from case precedent. Dr Choong will present pragmatic solutions using case studies approach during this 2 Days Malaysia Transfer Pricing 2018 seminar. 

With opportunities to meet up with friends and peers whom are equally interested in updating and learning the latest tax treats and tricks. Networking and catch up on the latest development, sharing of ideas and various solutions.



Highlight of the event is the 2 hours Q & A session from 5 – 7 PM. Where participants will address their own Transfer Pricing concerns and get them answered by the Tax Expert Dr Choong Kwai Fatt himself. Various companies has found this to be extremely useful and practical, in view that each company is distinct and the opportunity to tap into the speaker’s insight on issues arising in their company is priceless.

In addition, the questions asked and addressed by Dr Choong is a great learning opportunity for all participants, an eye opener and enhanced our skills and experience exponentially.

HRDF Claimable* – subject to employer obtaining prior approval from HRDF.

Early bird is applicable until 8th June 2018.

Group registration of three enjoys RM 200 off for each participant.

Group registration of five enjoys RM 400 off for each participant.

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More information about the venue

The seminar will be held in Ballroom, Level 5, The Gardens Hotel, Mid Valley City

Park in Zone B, Zone U or Premier parking zone which normally has adequate parking available or utilize the hotel valet option which is reasonably priced for all hotel guests.

Within the vicinity of one of Kuala Lumpur’s most popular shopping mall, it is ideal for outstation participants to bring along family to spend a weekend in Mid Valley City after attending seminar.

Flat rate of RM 5 per entry with validation for parking in Zone B, U or Premier parking zone.

roadmapAddress :

The Gardens, Mid Valley City, Lingkaran Syed Putra, 59200 Kuala Lumpur
Tel: 603 2268 1188 • Fax: 603-2284 8998


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Why participants love our tax seminars

Maybe you wil like us for the same reason

HRDF Claimable*

The Expert of the Experts

Seminars conducted by Synergy TAS PLT are eligible for HRDF claimable, *subject to prior application to HRDF by the employers.

We engage Dr Choong Kwai Fatt to conduct this 2 Days Malaysia Transfer Pricing 2018 seminar. Tap into the creative yet practical mind of Dr Choong himself.

Topics Expanding

10 CPD Awarded

Transfer Pricing, like Taxation is a field which grows continuously. With changes made continuously be it from the parliament, the court or the tax authority. The list of topic covered in this seminar is not exhaustive. We will add on new topics as it arises until the event to ensure we bring you a seminar packed with maximum Transfer Pricing ideas.

20 CPD is awarded and Certificate of Attendance based on that is to be issued. Our participants came from different professional bodies. We provide you a certification which is widely accepted by the various professional bodies. The final CPD accepted by professional bodies vary and subject to each bodies’ discretion.

2 Hours of Q & A

Let us do the muscle and brain work for you

This is the highlight of the event. 2 hours of non-stop QUESTION AND ANSWER by the expert on your corporate and tax concerns. Transfer Pricing is about knowing the strategy to apply in specific scenario to prepare the documentation in a legal manner. Sharing of such experience is paramount to us.

While you focus on revenue generating and operation, on things that matters, we do all the muscle and brain work just for you. We compile most up to date laws and the latest tax updates. Process and summarise them into understandable language. We develop, package and give you the relevant guides and references. What you need to do is just comprehend and apply them for Transfer Pricing.

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Frequently Asked Questions

Read on for questions commonly asked by participants


Yes, we do understand plans are always subject to change. Do provide us the name two weeks before the event date. If change of name was notify after we have printed the certificate, reprinting of cert can be done with a certificate reprinting administrative fee of RM 100.


We wish we can answer yes to this. Our seminar is based on latest and most update rules and regulations, with a cut off point of 1-2 weeks before the event. The earliest date to get the seminar materials is one week prior to event date. In this regard, we will have to turn down all request to deliver materials prior to event date.


We upheld Data Protection Act. We will not disclosed the information of who attended our seminar to third party. You are in good hands!


We provide 20 CPD for our this event, however professional bodies has its own internal rules.

Some of the professional bodies do limit the CPD claimed to 8 CPD per seminar day. This part is unfortunately beyond our control.

We trust the above clarifies your enquiries in relation to CPD. We thank you for your support and do drop by an email if you have further concerns.


+6016-302 6109 Call or email us any time Monday to Friday and we’ll help out!


Unfortunately, most of the session will not be repeated. Should there be a similar session, you can change to other session of the same event, subject to availability. Refund is not possible but replacement can be accepted prior to the event.



Yes, Dr Choong will first run through the principles. It is relevant for those who are new to this Transfer Pricing as well as those who are already aware of this area. The general principle is not difficult to follow. It is the analysis and application as well as the preparation of documentation which is the challenging.


We distinguish ourselves based on three areas. We are specialist in Tax Seminar.

We are reputable event organising company set up to organise advanced tax planning event and corporate management training. Our motto is to encourage the policy of “plan your tax, do not evade tax”.

Our well researched materials

Our participants mainly consist of corporate leaders, practitioners and senior executives, we hold firm to the view that we must do all it take to maximise learning and impact in minimum amount of time. We take pride in providing the most updated and well researched information. “We do the research, so that you do not have it”. Tax is a highly technical subject, we are known for compiling, complete sets of information needed for participants to refer after the event. Do expect to carry back to office at least a thick 2 inches file, in fact for this event reserve two file space for the seminar materials.

Best speaker

A speaker will make or break an event. Our seminars do attract the best talents in the industry, we are committed only to engage top speaker and subject matter expert for all events organised by us.

Our events are HRDF claimable* (*subject to application by participant)


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