● MIN CTPD 2026 FILE 20260116 Register →
Minimum Transfer Pricing Documentation 2026

Most TP reports are just decoration.
Yours should be defensible.

A 3-day working session with Dr. Choong Kwai Fatt. You won't sit through another passive update. You'll bring your group structure, financial statements and related-party data, and write a near-complete Minimum CTPD draft ready before YA 2025 submission.

DATE8, 9 & 10 July 2026
VENUEThe Gardens Hotel, Mid Valley, KL
CPD21 Points
HRDCClaimable · SBL Khas
Register Now → See the 3-day program
Section 01 — The Exposure

Transfer Pricing just moved from "good to know" to "must know."

RM20K–RM100K
Per Failure
Monetary penalties for late, incomplete, or non-standard CTPD — and they apply separately for each breach.
14days
Submission Window
Once the IRB issues a request letter, CTPD must be furnished within 14 days in the required format.
30–50%
Additional Penalty
On incorrect tax returns where pricing cannot be supported. The escalation is automatic.
2023Rules
Now Enforceable
Income Tax (Transfer Pricing) Rules 2023 + Malaysia TP Guidelines 2024 made contemporaneous TPD mandatory, not best practice.
Section 02 — Why this matters now

With e-invoicing live and full digitisation, related-party transactions are no longer buried in the notes.

The audit spotlight has shifted. Where transfer pricing once lived quietly in financial statement notes, it now sits in plain view across e-invoicing data, FAR analyses, and pricing policy documentation that must be dated and ready before the tax return is filed.

Companies that delay preparation, rely on weak reports, or cannot meet the 14-day submission deadline face the same heavy financial impact — regardless of intent.

Many finance and tax teams know TP is important but lack a structured, actionable framework they can immediately apply to their own group structure.

This is the gap. Existing TP trainings tend to be conceptual. Few are tailored to Malaysian rules for trading, services, financing, and investment holding companies under the 2023 Rules and 2024 Guidelines — and even fewer are hands-on.

This workshop is built specifically to close that gap.

While others struggle to learn the latest updates, you walk out not only aware of Minimum Transfer Pricing — you also have the right templates and working knowledge at your disposal. — Dr. Choong Kwai Fatt
Watch · 5-Minute Briefing

Rather see it first? Here's the five-minute version.

The CTPD problem most teams don't see coming, what the three days actually produce, and what your team walks out with. Narrated by Dr. Choong Kwai Fatt.

Dr. Choong Kwai Fatt — CTPD Explained briefing
▶ CTPD Explained · Watch on YouTube ↗
5:32
FILE · VIDEO BRIEFING — The CTPD problem, the 3-day working session, and the Day-3 deliverable. Opens on YouTube in a new tab.
Section 03 — The Workshop

This is not another passive TP update. It's a working file lab.

Over three days, you'll move from data compilation to FAR analysis to pricing policy formulation to writing the actual CTPD — using your own company's group structure and related-party data. By the end, you'll have draft documentation that reflects your business, aligned to the 2023 Rules and 2024 Guidelines.

Step 01

Data Compilation

Map group structure, controlled parties, and related-party transactions. Apply threshold tests to determine whether Full or Minimum TPD applies.

Step 02

Analysis & Review

Conduct FAR analysis with practical application. Segregate business vs non-business dealings. Identify the controlled transactions that matter.

Step 03

Policy Formulation

Develop and document pricing policies. Select the appropriate TP methodology — CUP, Cost Plus, RPM, or TNMM — and embed it into your charging structure.

Step 04

CTPD Writing

Draft Minimum CTPD initiation write-ups for goods, services, financing, and rental transactions. Walk out with the templates your IRB file actually needs.

Bring on Day 1

Participants are strongly encouraged to bring audited financial statements, preliminary group structure (worldwide and local), department profile, pricing policy, and details of related-party transactions. The writing and refinement happens across the three days — using your data, not hypotheticals.

Workshop reviewed

Three days. Your CTPD drafted. Before the YA 2025 deadline.

Register Your Team →
Early bird until 12 June 2026 · HRDC claimable
The Transition

Three days. The shape of your TP work, fundamentally changed.

The before-state

Scattered files, missing analyses, ambiguity. Fearing the IRB request letter and the penalty math.

The after-state

Group structure mapped. FAR analysis done. Pricing policy documented. CTPD drafted, dated, and defensible before YA 2025 submission.

Section 04 — Program

Three days. From raw data to defensible draft.

01
Day One

Practical approach to data collection, examination & review

Establish the foundations. Map the structure, identify the controlled transactions, and determine exactly which type of TPD applies to your business.

1.1
Business Activities & Group Structure

Understand the company's principal business activities and operating environment. Map and analyse the group organisation structure — local and overseas — and develop department profiles to support functional understanding.

1.2
Controlled vs Non-Business Dealings

Identify and document controlled and associated companies. Distinguish effectively between business and non-business dealings with related parties — including management services, loans and advances, and rentals.

1.3
Revenue & Financial Assistance Extraction

Extract and analyse annual revenue across business transactions, loans and advances (to/from related parties), and rental of movable and immovable properties. Evaluate financial assistance — loans, advances, and guarantees.

1.4
Threshold Tests & Documentation Type

Apply annual threshold tests to determine contemporaneous documentation requirements. Differentiate clearly between Full TPD and Minimum TPD. Recognise key features and distinctions across types — and determine when multiple TPDs apply within a single year.

1.5
The 20% Rule & Exclusion Cases

Identify key controlled transactions and apply the 20% rule effectively. Perform judgemental reviews on exclusion cases. Assess compliance conditions and documentation sufficiency.

1.6
Day 1 Output: Initial CTPD Write-ups

Prepare Minimum CTPD initiation write-ups focusing on group structure (local and worldwide) and management profile.

02
Day Two

Effectively writing contemporaneous CTPD content

Apply FAR analysis. Document trading, distribution, and rental transactions. Select and justify the appropriate TP methodology. Draft real CTPD content.

2.1
FAR Analysis in Practice

Conduct Function, Asset and Risk analysis with practical application. Define analysis coverage, scope, and application across your controlled transactions.

2.2
Trading of Goods — Domestic & Cross-Border

Document sales to controlled companies in Malaysia and overseas. Analyse purchases of goods from overseas related parties. Apply Comparable Uncontrolled Price (CUP) method — when and how — and evaluate Cost Plus implications.

2.3
Distributor Profiles & TP Implications

Identify distributor profiles and their TP implications: Limited Risk Distributor, Full-fledged Distributor, Commissionaire, Licensed, and Agent. Understand bulk-breaking and cost-sharing arrangements. Apply Resale Price Method (RPM) — consider TNMM as alternative.

2.4
Pricing Policies & Mechanisms

Develop and document pricing policies. Refine charging bases and pricing mechanisms. Embed selected transfer pricing methodologies into your pricing structures — not as theory, as documented policy.

2.5
Shareholders' Activities & Non-Deductible Costs

Review shareholders' activities and segregate non-deductible costs. Understand the IRB's focus on non-deduction risks — and how to position documentation accordingly.

2.6
Rental Transactions & Cost Plus Method

Document rental transactions for movable and immovable properties — charging basis and service tax application or exemption. Apply Cost Plus Method: cost component identification, mark-up determination, valuation bases, and allocation keys.

2.7
Day 2 Output: CTPD Initiation Write-ups

Draft Minimum CTPD initiation write-ups covering controlled transactions, pricing policies, and rental arrangements.

03
Day Three

Advanced & strategic writing for contemporaneous TPD

Unbundle management fees. Document core value services. Tackle financing transactions. Handle the high-risk areas where weak documentation triggers compounding penalties.

3.1
Unbundling Management Fees

Use a structured, defensible approach to unbundle management fees. Divide, segregate and filter services systematically. Apply the commercial reality test. Support deductions through agreements, justification and compliance evidence.

3.2
Core Value Services

Identify and assess core value services: strategic business development, brand management, sales and marketing leadership, treasury management, technical know-how and commercialisation of R&D, and strategic consultancy. Determine appropriate charging bases — headcount, revenue, time incurred — applying quantitative and qualitative analyses.

3.3
Low Value-Added Support Services

Identify low value-added support services. Focus on qualitative features and simplified charging basis — without weakening defensibility.

3.4
Financing Activities & Interest Benchmarking

Analyse loans and advances provided to controlled companies (Malaysia vs overseas). Evaluate interest-charging implications. Benchmark and justify interest rates using fixed deposit rates, bank lending rates, and base lending rates plus margins. Understand restrictions on interest-free arrangements.

3.5
Directors' Loans & Deemed Interest

Assess loans and advances to directors and the deemed interest income risks attached. Address interest restriction issues with documentation that holds up to scrutiny.

3.6
Cross-Border Loans & Withholding Tax

Analyse loans received from overseas related parties — with or without interest. Consider withholding tax implications. Apply earnings stripping rules effectively.

3.7
Day 3 Output: Complete CTPD Set

Prepare Minimum CTPD initiation write-ups for core value services, low value-added services, financing transactions, and investment holding companies.

Daily Rhythm

Same shape across all three days.

Sumptuous meals provided throughout. Q&A sessions accept anonymous questions, answered live by Dr. Choong — pre-empting challenges, surfacing practical solutions, and learning from each other's concerns.

Speaker is committed to high-quality presentation and insists all materials are covered. Schedule may vary.

09:00
Morning Session Opens
Core Principles & Scope
10:15
— Tea break · Sumptuous meals provided —
10:45
Mid-Morning Session
Analysis & Policy Formulation
12:30
— Lunch · Sumptuous meals provided —
14:00
Afternoon Session
Application & Frameworks
15:45
— Tea break · Sumptuous meals provided —
16:00
Late Afternoon Session
Hands-on Writing & Refinement
17:00
Q&A Session — Live
Anonymous submissions, answered by Dr. Choong
19:00
Close
Full Brochure · PDF

Take the full agenda with you.

Complete 3-day program, daily timings, speaker profile, pricing structure, and registration form — formatted for sharing with your CEO, finance team, or HRDC submission.

Download PDF ↓
No email required. Opens in a new tab.
Section 05 — The Distinction

Minimum TP vs Full TP — know which one applies before the request letter arrives.

★ File 01 · Min TPD
Approach A

Minimum TPD

  • Threshold-driven application based on annual revenue and transaction value tests
  • Focused documentation covering controlled transactions, pricing policy and FAR analysis
  • Faster to compile when the framework and templates are in place
  • Sufficient for many trading, services, and investment holding companies under the 2023 Rules
★ File 02 · Full TPD
Approach B

Full TPD

  • Required for larger companies, complex group structures and high-value related-party transactions
  • Adds three deeper analyses: industry/market conditions, TP method justification, and full FAR identification
  • More time-consuming and costly to prepare properly
  • Inadequate Full TP work — common in the market — can still fail to support pricing policy and create legal exposure

In plain CFO language: knowing which one applies is the difference between a focused two-week internal exercise and a delayed, expensive, externally-dependent scramble after an audit request lands.

Section 06 — Speaker Profile

The expert of experts in Malaysian tax implementation.

PORTRAIT · 2026 Dr. Choong Kwai Fatt
Dr. Choong Kwai Fatt teaching — vision gesture ★ Vision
Dr. Choong Kwai Fatt teaching — emphasis gesture ★ In Session
Dr. Choong Kwai Fatt
Tax Strategist · Author · Educator
B.Acc(Hons)(Malaya) · LL.B(Hons)(London) · CLP · MCL(IIUM) · PhD(IIUM) · FCCA(UK) · FCCS
Role
Tax Consultant, Advocate & Solicitor (High Court of Malaya)
Recognition
Appointed by the Ministry of Finance as panel member to review Tax Reforms in Malaysia, inclusive of GST formulation
Research
Extensive published research on Malaysian Taxation since 2006 — drawing on comparative study across international tax systems

Sought by listed companies, HNW individuals, and SMEs for strategies others don't see.

Dr. Choong is the pioneer in Tax Formation and an authority in tax law and implementation. He is constantly sought by listed companies, high-net-worth individuals, and SMEs for his practical and impressive tax strategies — and for his foresight into emerging tax concerns.

As an expert in tax planning, he has personally trained corporate accountants and professional firms on Income Tax, RPGT, GST, and SST implementation. His approach is unmistakable: clearly thought-out implementation plans, not abstract theory.

For this Minimum Transfer Pricing workshop, expect comprehensively compiled seminar materials, templates you can actually use back at the office, and the "unthinkable" strategies that have built his reputation.

Section 07 — Fit

This is built for companies that cannot afford TP blind spots.

+ Built for

  • CFOs and finance directors in companies growing toward listing status
  • Finance and tax leaders in listed Malaysian companies
  • Finance heads in fast-growing mid-tier SMEs with related-party transactions
  • Tax managers and accountants responsible for CTPD preparation
  • Partners and senior managers in tax and accounting firms advising clients on TP
  • Internal tax teams who want to bring CTPD preparation in-house

— Not built for

  • Companies looking for a passive theory-only TP update
  • Teams unwilling to bring real financial data and group structure to the session
  • Audiences seeking generic compliance training applicable to "all industries"
  • Anyone hoping for a quick certificate without doing the writing work
The Venue · Section 08

The Gardens Hotel,
Mid Valley City.

Three days in the centre of Kuala Lumpur. The Gardens Hotel sits within one of the country's largest commercial complexes — connected by both LRT and KTM, walking distance to Mid Valley Megamall, with valet parking and dedicated zones for delegate vehicles.

AddressLevel 5 Ballroom, The Gardens Hotel
AccessLRT & KTM · Valet · Zone B/U/Premier parking
Within ReachMid Valley Megamall · Boulevard Hotel
Section 08 — Logistics

Three days, the centre of KL, twenty-one CPD points.

Dates
8, 9 & 10 July 2026
Wednesday, Thursday & Friday
Time
9:00 AM – 6:00 PM
Daily, with breaks & lunch provided
Venue
The Gardens Hotel
Level 5 Ballroom, Mid Valley City — LRT & KTM accessible
Accreditation
21 CPD Points
HRDC Claimable — SBL Khas · No. 10001642692
Section 09 — Investment

Specialist team training. Pricing built for groups.

Early Bird Lock-in — Until 12 June 2026
★ Rate 01
1 – 2 Participants
RM5,200
RM 6,200 normal rate
Nett, per participant, for three days · Service Tax Inclusive
Early Bird Discount    −RM 1,000
Final    RM 5,200
★ Rate 02
3 – 4 Participants
RM4,900
RM 5,900 normal rate
Nett, per participant, for three days · Service Tax Inclusive
Early Bird    −RM 1,000
Group Discount    −RM 300
Final    RM 4,900
★ Rate 03
5 or More Participants
RM4,600
RM 5,600 normal rate
Nett, per participant, for three days · Service Tax Inclusive
Early Bird    −RM 1,000
Group Discount    −RM 600
Final    RM 4,600

HRDC Claimable — subject to employer's application to PSMB. As at time of publication, HRDC limits the amount claimable per participant to RM1,750 per day. Seats are confirmed on payment made and on a first-come first-served basis. Substitution allowed at no extra charge; reprinting service charge applies for name changes on certificates after issue.

Section 10 — FAQ

Before you register — the questions teams ask most.

Q.01 Who is this designed for — and who is it not for?

Designed for: finance leads, tax managers, CFOs, and partners at tax or accounting firms — typically attending in teams of 2 to 5 from the same company. The modules build on each other and assume real-world data is being brought in.

Not designed for: standalone attendees seeking passive CPD hours, generalist business audiences, or companies looking for "awareness-level" TP content. This is implementation work, not introduction. If your team is new to TP fundamentals, the Full TPD seminar is the better starting point.

Q.02 How is this different from a Full TPD seminar?

This workshop is specifically scoped to Minimum CTPD requirements — for companies that meet the threshold conditions but do not require Full TPD documentation. Different threshold tests apply, different documentation depth is required, and the defensibility posture is calibrated to the Minimum scope rather than the full one.

The "Min TPD vs Full TPD" section above covers the comparison in detail.

Q.03 What does my team walk out with on Day 3?

A drafted Minimum CTPD using your own group's data — not a hypothetical template. Group structure mapped. FAR analysis completed. Pricing methodology selected and justified. Specialist transactions (management fees, financing, withholding tax exposure) handled with a defensible structure.

Practical, hands-on approach. Your team doesn't just sit and listen. In this program your team is encouraged to work on your real data, your real company structure, and your real transactions — knowing what is important and what is just fluff. See the real transfer pricing challenges head-on and get practical answers to address them.

Plus 21 CPD points per participant, certificate of completion, and reference materials for the post-seminar finalisation work — so what you draft in the room continues to be useful when your team returns to the office.

Q.04 How does HRDC SBL Khas claiming work for this seminar?

The seminar is registered under HRDC SBL Khas (Employer Reference No. 10001642692). Your company can claim training expenses through the standard SBL Khas process — your HR department applies via the HRDC eTRiS portal before or after the session.

We submit all required invoicing, attendance records, and HRDC-compliant documentation for the claim. The 3-day duration and 21 CPD structure qualify under standard SBL guidelines. For employers contributing to the HRDC levy, there are also claims available for travel and accommodation — check with your internal HRDCorp coordinator for a more detailed breakdown.

Q.05 What if a registered participant cannot attend at the last minute?

Participant substitution is allowed up to 24 hours before Day 1. Notify us at event@synergytas.com or WhatsApp Janet directly, and we will update the registration record before the session begins.

Refunds for individual cancellations follow our standard policy. Contact us to discuss your situation — we are practical about genuine business changes.

Q.06 How does the team / group pricing work?

Three rates are available, all per participant, all service-tax inclusive, all HRDC-claimable: Early Bird (until 12 June 2026) at RM 5,000 / pax · Standard at RM 5,200 / pax · Group Rate (5 or more participants from the same company) at RM 4,600 / pax.

The group rate is the strongest value because the workshop is designed for team workflow — finance, tax, and leadership working through the same group data together. One person attending tends to bring back fragments. A team attending brings back a coordinated draft.

Q.07 What materials and post-seminar support are provided?

A printed workshop binder containing module worksheets, templates and slides, FAR analysis grids, method-selection frameworks, and CTPD draft outlines. Digital copies provided for ongoing internal use.

Certificate of completion stating the 21 CPD hours for each participant. Breakfast, refreshments, lunches, and tea breaks across the three days. 3 post-seminar Q&A submissions included — to cover the hiccups and sudden changes that surface after the session.

You can also opt into a coaching session, where Dr. Choong personally reviews your contemporaneous transfer pricing documentation and suggests improvements where needed.

Q.08 What language is the seminar conducted in?

The seminar is conducted entirely in English.

Q.09 Are dietary options catered? (Halal, vegetarian)

Yes. All meals across the three days are fully halal, with vegetarian options available on request. Notify us of any specific dietary requirements at the time of registration so we can confirm with the venue's catering team in advance.

Q.10 Can we attend remotely, or is in-person mandatory?

In-person only. For intimate working sessions on real group data and sensitive transaction structures, the work is better done behind closed doors — not over a video call. This is a deliberate design choice, not a logistical limitation.

Q.11 Is there a corporate invoice or PO option for payment?

Yes. Upon registration, a tax invoice is automatically generated in your company's name and emailed to the contact provided. Standard corporate payment terms apply. PO numbers can be referenced — include yours at the time of booking or send it through to event@synergytas.com.

Q.12 Is Dr. Choong available for follow-up consultation after the seminar?

Yes, on an appointment basis. Consultation fees are quoted separately, based on the complexity of the matter. Contact event@synergytas.com with a brief outline of your question and we will arrange a suitable time and quote.

Other questions? Email event@synergytas.com or call Janet at +6 016 302 6109.

Don't wait for the IRB request letter to find out your TP file is decoration.

Three days. One expert. Your own group data. Walk out with a Minimum CTPD draft ready before YA 2025 submission.

Register Your Team →
8–10 July 2026 · The Gardens Hotel, KL · Seats limited · First come, first served