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Foreign Subsidiaries

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Foreign Subsidiaries

Do you have all the necessary transfer pricing policies and risk assessments in place for the intercompany related party transactions of your foreign subsidiaries?

Ask us how we can assist you with:

  • Transfer pricing planning and implementation of new business structures
  • Preparation of transfer pricing documentation, Master File and Local File
  • BEPS and Country by Country Reporting implementation
  • Development and review of transfer pricing policy
  • Transfer pricing risk reviews, APAs and audit defense
  • Benchmarking studies covering all types of transactions and regions with access to databases
  • Preparation and review of intercompany agreements
  • Fast-track intercompany agreement drafting 
  • In-house transfer pricing workshops and training sessions
  • In-house transfer pricing advisory


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6 Aug

Malaysia’s New Transfer Pricing Guidelines on Controlled Financial Transactions: Intra-Group Loans

On 30 July 2026, the Inland Revenue Board of Malaysia (IRBM) released its new Malaysia Transfer Pricing Guidelines on Controlled Financial Transactions: Intra-Group Loans (MFTIL). The guidance provides a comprehensive framework for assessing, pricing and documenting intra-group loans under Malaysia’s transfer pricing regime.


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23 Jul

Why Forums Like the Singapore Tax Congress Matter

Adriana Calderon shares her perspective on the evolving tax landscape and the role of collaboration at the SCTP Singapore Tax Congress.


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23 Jul

IRAS Clarifies the Scope of Related Parties for RPT Reporting

The Inland Revenue Authority of Singapore (IRAS) has updated its Frequently Asked Questions relating to the Reporting of Related Party Transactions (RPT Form), providing additional clarification on the scope of entities and individuals that may be regarded as related parties for reporting purposes.


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