“Insights into Managing Transfer Pricing: A Legal Perspective” was the theme for a specialised talk on the BEPs Action Plan 13: Country-by-Country Reporting (CbCr) in Malaysia. The talk was delivered by S.Saravana Kumar, Partner in Tax, GST & Customs Practice of Lee Hishammuddin Allen & Gledhill.
On 27th January, Malaysia joined 30 other countries in signing the Multilateral Competent Authority Agreement (MCAA) for the automatic exchange of Country-by-Country reports (CbCr).
The MCAA is consequent to the OECD’s Base Erosion and Profit Shifting (BEPS) Action Plan 13.
In November 2015, the Inland Revenue Board (IRB) announced that it was following the BEPS development closely.
Despite cautioning that not all BEPS recommendations are relevant in the context of Malaysian tax policies, the IRB did underline the need for a robust transfer pricing (TP) monitoring plan.
CbCr can be used by country tax administration to assess high-level TP risks and other base erosion and profit-shifting related risks. This includes assessing the risk of non-compliance by members of the MNE group with applicable TP rules.
BMCC members were amongst the attendees to this unique tax insights presentation from a professional speaker, before enjoying a lunch and networking session at LHAG’s office.