As part of the Budget bill for 2021 (Finance Bill 2020), Malaysia is introducing new transfer pricing penalties that will apply from 2021. This includes the introduction of a new penalty MYR 20,000 to 100,000 for failing to furnish contemporaneous transfer pricing documentation, as well as the introduction of a 5% surcharge on the amount of any transfer pricing adjustments. In addition, new recharacterization powers will be introduced with respect to controlled transactions in order to streng…