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01
Transactions that may attract TP attention
Management or service fees
Parent company charges IT, HR or management support to a subsidiary.
Related party loans
Shareholder or group company loans, interest or interest-free arrangements.
Goods or asset transfers
Group sales of inventory, equipment, IP or licences.
02
What arm's length means
In simple terms, ask what independent third parties would have charged, paid or agreed under comparable circumstances. If the price is far from commercial reality, LHDN may ask for support.
03
Common owner mistakes
No agreement
Only bank transfers exist, without service agreements, loan agreements or invoices.
No pricing basis
Management fee, royalty, service fee or interest has no calculation method.
Documents prepared too late
Waiting for LHDN queries makes it harder to prove the original business judgment.
04
VSG recommendation
If your company has group companies, director/shareholder transactions, intercompany loans or cross-border service fees, ask your tax adviser whether TP documentation or supporting analysis is needed.
05
Official sources and disclaimer
This guide is for general educational purposes only and is not tax advice. Tax rates, deductions, filing deadlines and incentive eligibility may change and depend on each company's facts. Please consult a tax professional or refer to the latest LHDN guidance before making decisions.