Tan Chin Teck leads the transfer pricing team at BDO Malaysia. It provides advisory services on transfer pricing compliance and advisory matters. In addition, it supports clients in the development of inter-company TP policies, reviewing intra-group services and agreements, advance pricing agreements, TP audit management and TP dispute resolution. It serves local and multinational clients and has strengths in sectors such as manufacturing, chemicals and plantations. 

During the research period, the team was active in handling transfer pricing audit matters for various clients. Work including preparing transfer pricing documentation and liaising with the Inland Revenue Board of Malaysia on the information required for the audit. 

The team welcomed Lim Zheng-Shan as associate director during the research period. Before joining BDO, Lim worked at KPMG Malaysia. 

Client feedback 

“Well known for the areas of transfer pricing requirements and are able to advise us on areas for compliance.”

The tax team at Crowe Malaysia delivers tax services including corporate income tax, international tax, tax disputes and indirect tax. It also provides a full suite of transfer pricing services, including transfer pricing documentation and audit defense, for clients in Malaysia, Singapore and Cambodia. Partner Foo Meng Huei heads the tax compliance and transfer pricing groups. Foo has vast experience in advising tax audit and investigation matters.  

The team recently served as a tax due diligence advisor for the client's IPO exercise purposes. It conducted a full-scope tax due diligence exercise which includes direct tax, indirect tax, employee tax obligations and transfer pricing. It also served as project manager and supported the client’s other subsidiaries located in Singapore, Korea, Philippines and Vietnam, for tax due diligence reports. 

Executive director Mervyn Ong left the firm to set up his own tax practice during the research period. 

Client feedback 

“They took the time to understand our problem and requirements.” 

The tax practice at Deloitte led by Kwang Gek Sim is comprised of 24 tax partners and more than 600 tax professionals. Its practices include international tax, M&A, private clients, transfer pricing and indirect taxes. Regarding its indirect tax services, it supports GST, SST, customs dispute resolutions, audits and tax planning. It recently set up a new tax management consulting service line to support clients with tax automation and implementing centralised tax management systems. 

Details of the firm’s clients and recent work remain confidential. 

Halim Hong & Quek tax team launched in 2022 with the addition of the tax partner Desmond Liew Zhi Hong. It provides advisory services regarding all aspects of Malaysian taxation matters, including corporate tax, stamp duty, sales and service tax, digital service tax, goods and services tax and customs. It is also capable of representing clients before all levels of court, Special Commissioners of Income Tax and Customs Appeal Tribunal. 

Details of the firm’s work and clients remain confidential. 

Client feedback 

“Met our expectations and assisted us rightly.” 

“Going the extra mile to resolve matter for the best interest of the client.”

The team led by Soh Lian Seng offers services including corporate tax, global mobility services, tax dispute resolution, transfer pricing and indirect taxes. The corporate tax practice covers tax compliance and advisory services. It specialises in advising clients on the areas of inbound and outbound investments, M&A, international tax advice, tax due diligence and tax diagnostic review. 

A recent example of the firm’s work saw it serving as a tax advisor to a Malaysian conglomerate in tax structuring and IPO matters. It was involved from the stage of internal restructuring to reposition the client with businesses in agriculture, property development, property investment, green energy and provision of services into a pure agriculture player, to maximize its value.

Partner S Saravana Kumar is the head of the tax practice. He specialises in tax litigation and transfer pricing. The team supports a wide range of tax services, including sales and service tax, customs duty, transfer pricing, double taxation treaties, permanent establishments, real property gains tax, petroleum income tax and stamp duty. It is experienced in representing clients in cases before the Special Commissioners of Income Tax, High Court, Court of Appeal and the Federal Court. It also represents clients in various trade actions or investigations in respect of anti-dumping, safeguard duties, countervailing duties, anti-circumvention, free trade agreements and cross-border transactions. 

A team led by Datuk DP Naban and Kumar recently served as counsel and solicitor for the Tenaga Nasional Berhad in an ongoing tax dispute that involved RM 9 billion. The High Court ruled in favor of the client and the case is currently pending appeal before the High Court. 

Client feedback 

“RDS is the preferred legal firm for any tax or customs related issues or disputes - efficient, professional and competent.” 

“RDS ensure that they fully understand the issues which are under dispute, and they are thoroughly prepared to fight the case and there are no surprises sprung by the revenue. They are always amply prepared for litigation as compared to their Inland Revenue counterparts.” 

The tax and revenue practice at Skrine is led by Preetha Pillai and the team provides diverse revenue solutions to address client’s tax objectives. It advises and represents clients in court and before the relevant tribunals on matters related to corporate tax, sales and service tax, real property gains tax, employment tax, stamp duty, customs duties and excise, anti-dumping and safeguards, and rates and assessments. It also supports services for navigating tax audits and investigations. 

During the research period, Pillai and the team served as leading counsel and represented the Customs and Tax Administration of the Kingdom of Denmark, the plaintiff in civil suits against multiple Malaysian entities and related individuals to recover approximately RM 1 billion.

Adriana Calderon is the Co-founder of Transfer Pricing Solutions Malaysia and Hong Chuan Tan is the technical lead in Malaysia. The team supports clients with transfer pricing planning, documentation requirements, planning and compliance related to BEPS action plans, and audit defences. In addition, it is also capable of local, regional, and global benchmarking services. 

A recent example of the firm’s work saw it supporting a client in the tourism industry with transfer pricing advisory and compliance services. The work included providing cost-effective quality solutions to the client.

The tax team led by Adeline Wong has strong advisory and contentious capabilities. Its tax practice covers local and international tax planning, global structuring, M&A, indirect tax, supply chain structuring and optimisation and tax controversy. Its transfer pricing team led by Krystal Ng offers services including transfer pricing documentation, benchmarking, valuation, audit and defense. Other key professionals include Yvonne Beh and Jason Liang, who lead the indirect tax and tax controversy practice respectively. 

Details of the firm’s work and clients remain confidential. 

Client feedback 

“The team is professional and responsive. In addition, they provide value to the client by giving both practical and technical advice so that the client can make a complete and all-round assessment on its options.” 

“The Wong & Partners Team is knowledgeable and well informed on the tax issue at hand. They are confident on their legal interpretation and willing and daring to challenge the authority on their flawed re-interpretation of it. The team is dynamic, energetic and positive.” 

“Professional interaction with timely responses. Communicative. They are staffed with knowledgeable legal professionals who have in depth experience to address key audit areas. Proactive in offering solutions for discussion and good follow through to resolution.” 

“Responsive and reasonably well-thought-through advice.” 

“Wong & Partners generally responded promptly with practical advice (not just sticking to tax regulation).”