Malaysia Issues Transfer Pricing Guidelines on Intra-Group Loans

The Inland Revenue Board of Malaysia (IRBM) has published Malaysia Transfer Pricing Guidelines Controlled Financial Transactions: Intra-Group Loans, dated 30 July 2026. The guidelines provide comprehensive guidance on the specific transfer pricing requirements for intra-group loans and the determination of whether an intra-group loan is consistent with the arm's length principle, as required by the Income Tax Act 1967 (ITA), the Income Tax (Transfer Pricing) Rules 2023, and the Malaysia Tran…