Mastering Transfer Pricing Benchmarking and Comparability Study

About This Programme

Many companies and finance or tax personnel tend to assume that transfer pricing benchmarking is merely a database search exercise followed by documenting the resulting profit margins. In reality Transfer pricing benchmarking is one of the most complex components of Transfer Pricing Documentation because it requires careful alignment between functional analysis, the tested party, the transfer pricing method, and the selection of comparable companies. It involves significant professional judgement guided by the principles of the OECD and Malaysia Transfer Pricing Guidelines. Many benchmarking studies prepared contain technical gaps such as weak functional analysis, inappropriate screening criteria, or poorly justified comparables. These weaknesses create opportunities for the LHDN to challenge the reliability of the analysis, reject the comparables used, and impose adjustments that may increase a company’s tax exposure. This training aims to equip participants with a practical approach to conducting robust comparability analyses, enabling them to select defensible comparables, strengthen benchmarking documentation, and reduce the risk of transfer pricing adjustments during tax audit.