Rules needed to clarify transfer pricing landscape.

This article discusses a proposal to introduce specific transfer pricing legislation in Malaysia in 2009. It highlights the inclusion of transfer pricing provisions in the Income Tax Act 1967 (ITA) through the Finance Act 2009. It explores the issuance of transfer pricing guidelines by the Inland Revenue Board (IRB). It also indicates the reasons for raising questions as to how taxpayers could be expected to comply with the transfer pricing expectations of the IRB, including the lack of transparency and legal principles in the determination of the arm's-length principle of the board.