Transfer pricing case study: From the prespective of IRBM multinational tax branch

Globalisation, borderless world as well as multinational corporations (MNCs) have brought attention to the importance of transfer pricing, issues which commonly discussed in developed countries, to Malaysia especially when it always associated with tax avoidance. Hence, this study examines, first,...

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Main Author:	Zanariah, Baharim
Format:	Thesis
Language:	eng eng eng
Published:	2020
Subjects:	HJ4771.6 Income Tax Tax Returns. HM Sociology.
Online Access:	https://etd.uum.edu.my/9639/1/s825150_01.pdf https://etd.uum.edu.my/9639/2/s825150_02.pdf https://etd.uum.edu.my/9639/3/s825150_references.docx
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id	my-uum-etd.9639
record_format	uketd_dc
spelling	my-uum-etd.96392024-03-19T00:57:07Z Transfer pricing case study: From the prespective of IRBM multinational tax branch 2020 Zanariah, Baharim Mohamad Yusof, Nor Zalina Tunku Puteri Intan Safinaz School of Accountancy (TISSA) Tunku Puteri Intan Safinaz School of Accountancy (TISSA) HJ4771.6 Income Tax. Tax Returns. HM Sociology. Globalisation, borderless world as well as multinational corporations (MNCs) have brought attention to the importance of transfer pricing, issues which commonly discussed in developed countries, to Malaysia especially when it always associated with tax avoidance. Hence, this study examines, first, the methods of transfer pricing used by MNCs to reduce the amount of taxes paid; and second, to what extent the MNCs are legitimately paying their fair share of tax in Malaysia. Data collected from the tax authority are real transfer pricing cases audited by the IRBM Multinational Tax Branch (MTB). Three (3) case studies with three (3) different headquarters abroad which represents different business characterization were chosen. The analysis shows how MNCs have applied different transfer pricing method to prove that their transaction is at arm’s length basis. Further examinations of the most appropriate transfer pricing methodology applied were carried out. The analysis reveals how different treatment between tax regulation and practices implemented by MNCs could result in huge tax losses for the country. In their perspective, MNCs have disclosed legitimately all available information. As for tax authorities, there are tax gaps and loopholes that cause different treatment between the transacted countries/parties. Therefore, Section 140 prior to 2009 and Section 140A of the Income Tax Act 1967 with an effective date from the year 2009, acted as the general anti-avoidance provision to shelter tax avoidance scheme in Malaysia. 2020 Thesis https://etd.uum.edu.my/9639/ https://etd.uum.edu.my/9639/1/s825150_01.pdf text eng public https://etd.uum.edu.my/9639/2/s825150_02.pdf text eng public https://etd.uum.edu.my/9639/3/s825150_references.docx text eng public other masters Universiti Utara Malaysia
institution	Universiti Utara Malaysia
collection	UUM ETD
language	eng eng eng
advisor	Mohamad Yusof, Nor Zalina
topic	HJ4771.6 Income Tax Tax Returns. HM Sociology.
spellingShingle	HJ4771.6 Income Tax Tax Returns. HM Sociology. Zanariah, Baharim Transfer pricing case study: From the prespective of IRBM multinational tax branch
description	Globalisation, borderless world as well as multinational corporations (MNCs) have brought attention to the importance of transfer pricing, issues which commonly discussed in developed countries, to Malaysia especially when it always associated with tax avoidance. Hence, this study examines, first, the methods of transfer pricing used by MNCs to reduce the amount of taxes paid; and second, to what extent the MNCs are legitimately paying their fair share of tax in Malaysia. Data collected from the tax authority are real transfer pricing cases audited by the IRBM Multinational Tax Branch (MTB). Three (3) case studies with three (3) different headquarters abroad which represents different business characterization were chosen. The analysis shows how MNCs have applied different transfer pricing method to prove that their transaction is at arm’s length basis. Further examinations of the most appropriate transfer pricing methodology applied were carried out. The analysis reveals how different treatment between tax regulation and practices implemented by MNCs could result in huge tax losses for the country. In their perspective, MNCs have disclosed legitimately all available information. As for tax authorities, there are tax gaps and loopholes that cause different treatment between the transacted countries/parties. Therefore, Section 140 prior to 2009 and Section 140A of the Income Tax Act 1967 with an effective date from the year 2009, acted as the general anti-avoidance provision to shelter tax avoidance scheme in Malaysia.
format	Thesis
qualification_name	other
qualification_level	Master's degree
author	Zanariah, Baharim
author_facet	Zanariah, Baharim
author_sort	Zanariah, Baharim
title	Transfer pricing case study: From the prespective of IRBM multinational tax branch
title_short	Transfer pricing case study: From the prespective of IRBM multinational tax branch
title_full	Transfer pricing case study: From the prespective of IRBM multinational tax branch
title_fullStr	Transfer pricing case study: From the prespective of IRBM multinational tax branch
title_full_unstemmed	Transfer pricing case study: From the prespective of IRBM multinational tax branch
title_sort	transfer pricing case study: from the prespective of irbm multinational tax branch
granting_institution	Universiti Utara Malaysia
granting_department	Tunku Puteri Intan Safinaz School of Accountancy (TISSA)
publishDate	2020
url	https://etd.uum.edu.my/9639/1/s825150_01.pdf https://etd.uum.edu.my/9639/2/s825150_02.pdf https://etd.uum.edu.my/9639/3/s825150_references.docx
_version_	1794023765994110976

Transfer pricing case study: From the prespective of IRBM multinational tax branch

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