The Inland Revenue Board of Malaysia (IRBM) has published the Malaysia Transfer Pricing Guidelines 2025, dated 31 July 2025, which update and replace the Malaysia Transfer Pricing Guidelines 2024, dated 24 December 2024. The main change in the updated guidelines concerns the penalty and surcharge structures for transfer pricing audit adjustments.
The penalty structure provides for a 100% penalty on tax undercharged in the event of understatement or omission of income as a result of audit f…