06/08/2026
The IRB continues to eye interest-free intercompany loans with significant transfer pricing adjustments.
In our second TP Audit Insights case study, we unpack a real transfer pricing audit involving a Malaysian public listed company and its interest-free intra-group financing arrangements.
The audit involved:
💰 Scrutiny over interest-free advances provided to subsidiaries
🔍 Questions on whether the arrangements represented debt financing or equity support
📊 Assessment of whether arm’s length interest should have been charged
⚖️ Review of the economic substance behind the funding structure
The IRB proposed a transfer pricing adjustment, but the outcome depended on more than how the transactions appeared on paper.
Authored by our Transfer Pricing Partner Sylvia Song, our latest article breaks down the audit findings, defence approach, and key lessons businesses should consider when structuring and documenting related-party financing arrangements.
Read the full case study → https://tinyurl.com/crowe-tp-case-2