By Mr. Hari Ramulu Munusamy
18 October 2019, 9:00 am to 5:00 pm
Kuala Lumpur
(100% Claimable From HRDF/PSMB)

Transfer pricing strategies play an important role in key business performance areas such as optimizing tax efficiency, reducing legal exposure/risks and increasing cash flow. Gain an understanding of IRB’s new section 140A and how it impacts you.

A majority of the world’s cross-border transactions now occur through related entities, bringing with it various tax and business concerns. Hence, transfer pricing strategies play an important role today in key business performance areas such as optimizing tax efficiency, reducing legal exposure/risks and increasing cash flow.

In Budget 2009, IRB introduced the new section 140A in the Income Tax Act, 1967 on “Transfer Pricing”. This new section in the legislation has major tax implications on related party transactions in Malaysia. In addition, new transfer pricing rules and guidelines have been issued to supplement the new Section 140A.

This program will show you the groundwork that needs to be put in place in order to comply with the IRB’s guidelines, and to stay within the law.

The objectives of the seminar are to provide:
  • Discuss key issues related to Transfer Pricing and record keeping that meet IRB’s requirements
  • Identify key technical, issues and factors in supporting the arm’s length nature of related party transactions
  • Keep abreast with the latest updates on legislation and guidelines issued by IRB on Transfer Pricing in Malaysia

Directors, Financial Controllers, Finance Managers, Accountants, Tax Consultants, Tax Practitioners/Advisors, Company Secretaries.


Lectures, PowerPoint presentations, discussions and case studies.

    • Scope of TP Rules and Guidelines
    • Meaning of control and associated
    • Meaning of arm’s length principle
    • Determination of arm’s length price
    • Factors determining comparability
    • Different TP methodologies in arriving at arms’ length price
    • TP adjustment by DGIR
    • Compensating adjustment
    • Intragroup services
    • Cost contribution arrangement
    • Intangible properties
    • Intragroup Financing (Loan)
    • Interest on financial assistance
    • Retention of records
    • Contemporaneous TP documentation
    • Penalty
    • New form on Cross Border Transactions by IRB (Form MNE)
    • Scope of APA Rules and Guidelines
    • APA process
    • Withdrawal of APA
    • Effect of APA
    • Request for rollback
    • Filing of APA compliance report
    • Revision/Cancellation/Revocation/Renewal of APA
    • Form APA1 and APA2
Your Trainer

Mr. Hari Ramulu A/L Munusamy, FCCA[UK], CA[M], CMIIA, ACTIM, Associate of ACFE[USA], Associate of MACFE, Member of MATPRO, Member of IMA, Member of MIHRM, Member of MAPS, MBA [Accounting] is a Chartered Certified Accountant, with wide experience in audit private practice and in financial/management/public sector accounting, auditing and taxation educational process, having been in the profession and industry since October 1974.

He started his career with Messrs: F.H.Eiles & Co., a firm of Chartered Accountants in London as an Audit Assistant in October 1976 (after Diploma in Accounting, Newcastle-Upon-Tyne). Subsequently, he continued his career as an Audit Supervisor with Messrs: Coopers & Lybrand (now known as PricewaterhouseCoopers), Kuantan in May 1984. In January 1986 he joined Messrs: Senthe & Co (a firm of Chartered Accountants in private practice in Petaling Jaya), as an Audit Manager, till December 2006. He had also worked as a group accountant for FARMCO Sdn. Bhd. He had lectured at various institutions of higher learning, as a part-time and full-time lecturer, from October 1988 till June 2014.

Over the years, he gained knowledge, experience, skills and expertise in accounting, auditing and taxation related services including tax investigation, forensic accounting and company valuation and floatation.

He is deemed to be a prolific speaker/presenter with excellent commendations from participants, at seminars, workshops, conferences. He has several public appearances relating to taxation, costing, budgeting, financial statements analysis, accounting standards, preparation of financial statements, financial statements fraud, forensic accounting and GST (pre and post implementation).

Professionally, he is a Fellow member of the Association of Chartered Certified Accountants of UK, a Chartered Accountant of the Malaysian Institute of Accountants, an Associate member of the Malaysian Chartered Institute of Taxation, a Chartered member of the Institute of Internal Auditors of Malaysia (affiliate of USA), an Associate member of the Association of Certified Fraud Examiners of USA, associate member of MACFE, member of MATPRO, member of IMA and a member of MAPS. His academic excellence is in the form of (a) Diploma in Accountancy (Newcastle-Upon-Tyne, England), and (b) Master of Business Administration (Accounting) from University of Newcastle, USA.

Course Fee
(Course fee is inclusive of 2 tea breaks, lunch, course material,Certificate of Attendance)
1 person ~ RM 848 / pax
2 persons or more ~ RM 742 / pax
(Course fee is inclusive of 2 tea breaks, lunch, course material, Certificate of Attendance and 6 % Service Tax )
Terms & Conditions:
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Registration is confirmed once registration form is received via fax/email/mail. All Payments/Undertaking Letters/Local Order (LO)/Letter of Approval must be made available and presented prior to the course.
2. Cancellation Policy
Any cancellation must be received in writing within 5 working days prior to the event else 30% payment will be imposed. Any no-show by registered delegates will be liable for full payment of the program fees.
3. Disclaimer & Program Changes Policy
Scientia Training Sdn Bhd reserves the right to amend or cancel the event due to circumstances beyond its control. We reserved the right to modify the advertised topics or course timing whenever necessary.
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