Malaysia Amends Transfer Pricing Rules, Including Simplified Definition of MNE Group and New Corresponding Adjustment Rule

Malaysia published the Income Tax (Transfer Pricing) (Amendment) Rules 2026 in the Official Gazette on 27 August 2026, which amends the Income Tax (Transfer Pricing) Rules 2023. One of the main amendments is the introduction of an entirely new definition of "Multinational Enterprise Group" for the purpose of the contemporaneous transfer pricing documentation requirements (Rule 4). The definition is simplified, providing that "Multinational Enterprise Group" means a group of associated enterp…