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What is Contemporaneous TP Documentation?

Updated: Dec 18, 2022

Preparing Contemporaneous Documentation originated in the United States in the early 1990s.

A taxpayer who fails to provide contemporaneous transfer price documentation within 30 days of the Director General's request will be guilty of an offence under section 113B of the Income Tax Act 1967 beginning on 1 January 2021.

Upon conviction, the taxpayer is subject to fines of not less than RM20,000 and not more than RM100,000 or to imprisonment for a term not exceeding six months or to both. 

The taxpayer may file an appeal with the Special Commissioners of Income Tax when fines are imposed without prosecution [s 113B(5)].