The introduction of Income Tax (Transfer Pricing) Rules 2023. (P.U. (A) 165 ("the PUA")

The PUA has effect for the year of assessment 2023 and subsequent years of assessment and shall apply to a controlled transaction mentioned under subsection 140A(2) of the Income Tax Act 1967.

For the purposes of determination and application of arm’s length price, a person shall determine and apply the arm’s length price for the acquisition or supply of property or services in accordance with the manner provided in the PUA.