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All you need to know about transfer pricing documentation.
Adriana Calderon, Managing Partner - Asia & Malaysia at Transfer Pricing Solutions, shares insights from the IFA APAC Conference in Tokyo, highlighting key trends in transfer pricing across Asia. She explores regional differences in approach, increasing regulatory complexity, and rising audit activity, while reflecting on the importance of global networks in fostering collaboration and shaping the future of international tax.
Malaysia’s transfer pricing framework continues to evolve, with the Inland Revenue Board of Malaysia applying increasing scrutiny to how multinational groups price, document and defend related‑party transactions. For businesses operating in Malaysia, transfer pricing has become a core tax risk area rather than a routine compliance exercise.
Across Asia, transfer pricing audits are becoming more frequent, more detailed and more analytically driven. Tax authorities are no longer limiting their reviews to whether documentation exists. Instead, they are interrogating whether transfer pricing outcomes genuinely align with commercial reality, operational substance and financial results over time.
As tariff wars intensify, government deficits balloon, and supply chains fragment, the OECD’s 15% global minimum tax has shifted from a technical compliance issue to a strategic imperative reshaping how and where multinational enterprises compete.
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The Berry Ratio may sound light‑hearted, but in transfer pricing it is one of the most debated Profit Level Indicators (PLIs) used under the Transactional Net Margin Method (TNMM). Simple in formula yet demanding in application, the Berry Ratio continues to attract scrutiny from tax authorities worldwide.
Geopolitical volatility has moved from the margins of risk management to the centre of transfer pricing strategy. For multinational groups operating across Australia, Asia and Europe, geopolitical turmoil is no longer a short-term disruption to be explained away in annual documentation.
Singapore’s Budget 2026 sets out a clear strategy to strengthen competitiveness in a changing global environment. The Budget introduces important tax measures while confirming Singapore’s implementation of OECD Pillar Two global minimum tax rules.
Across Asia-Pacific, multinational groups are facing increasing complexity as tariff measures and transfer pricing rules begin to overlap more directly.
US‑based multinational enterprises (MNEs) will continue to be subject to Singapore’s Qualified Domestic Minimum Top-Up Tax (QDMTT), even though they may not be subject to a top‑up tax under US rules.
Starting May 2026, in-scope multinational enterprise (MNE) groups must register for Singapore’s Multinational Enterprise Top-up Tax (MTT), Domestic Top-up Tax (DTT), and the GloBE Information Return (GIR) under the Multinational Enterprise (Minimum Tax) Act 2024.
