Quick answer: Malaysian businesses with controlled transactions may need either full or minimum transfer pricing documentation (TPD). Full contemporaneous transfer pricing documentation (CTPD) is required when the current income and controlled-transaction thresholds are met. Other non-exempt taxpayers may prepare minimum CTPD, but every related-party transaction must still follow the arm’s-length principle.
This guide explains the difference so finance teams can choose the correct documentation level before an LHDN request arrives.
Full CTPD versus minimum CTPD at a glance
| Question | Full CTPD | Minimum CTPD |
|---|---|---|
| Who prepares it? | Businesses meeting the full-documentation thresholds | Non-exempt businesses below the full thresholds |
| Main purpose | Complete analysis of the group, business and controlled transactions | Focused support for the Malaysian business and its related-party dealings |
| Key content | Group overview, business information, controlled transactions, functional analysis, pricing method and comparables | Business information, controlled transactions, pricing policy and relevant supporting evidence |
| When must it be ready? | Completed and dated before the tax-return due date | Completed and dated before the tax-return due date |
| LHDN submission deadline | Within 14 days from service of a written notice | Within 14 days from service of a written notice |
When is full transfer pricing documentation required?
Under the Malaysia Transfer Pricing Guidelines 2024, full CTPD is required where either of these tests is met:
- Gross business income exceeds RM30 million and cross-border controlled transactions total RM10 million or more for the year; or
- Controlled financial assistance exceeds RM50 million for the year.
Controlled financial assistance includes related-party loans and other financing arrangements. The thresholds must be reviewed every year because business income and transaction values can change.
Who may prepare minimum CTPD?
A person with controlled transactions who is not exempt and does not meet the full-CTPD thresholds may choose to prepare minimum CTPD. “Minimum” does not mean a brief memo prepared after an audit notice. The file should still explain the business, identify the related parties, quantify each transaction and show why the pricing is arm’s length.
Businesses should retain agreements, invoices, calculations, allocation keys, correspondence and evidence that services or financing were genuinely provided. LHDN may ask for more information if the minimum file does not support the tax position.
Who may be exempt from preparing CTPD?
Current exemptions include persons whose total controlled transactions do not exceed RM1 million and certain persons with solely domestic controlled transactions. The domestic exemption is subject to conditions, including the parties’ tax rates, tax-incentive status and recent loss position. Even where an exemption applies, the arm’s-length principle and normal record-keeping requirements remain.
Use HTL’s separate guide on who must prepare CTPD in 2026 for the full decision sequence.
What should a finance team do now?
- Map every related party and controlled transaction for the year.
- Calculate operational and financial-assistance values separately.
- Check whether an exemption applies and document the reason.
- Determine whether full or minimum CTPD is required.
- Complete and date the file before the tax-return due date.
- Keep an LHDN-ready copy that can be furnished within 14 days.
Businesses with complex cross-border dealings, recurring management fees or intercompany financing should not wait for an audit request. HTL’s transfer pricing services can help assess the required documentation level, while the Malaysia transfer pricing guide explains the broader framework.
This article provides general information and is not a substitute for advice based on a specific transaction or tax position.
