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Krystal Ng

Krystal Ng is a partner in the Tax, Trade and Wealth Management Practice Group of Wong & Partners with over 10 years of experience. Her primary focus is on tax and transfer pricing issues in the context of crossborder transactions as well as post-mergers and acquisitions integration for multinational clients in a wide range of industries.
She has been recognised as a Next Generation Partner by Legal 500 Asia Pacific 2023, and is named as Up and Coming for Tax in Chambers Asia Pacific 2023. In the Chambers guide, clients commend her for being "a very responsive and knowledgeable tax consultant." She was also awarded the Tax Rising Star award by Euromoney Women in Business Law Awards Asia Pacific 2022.
Krystal's practice extends to the provision of strategic tax advice on a broad range of subjects such as income tax, double tax treaties, withholding tax, real property gains tax, assisting with tax incentives and exemptions as well as the planning and management of transfer pricing considerations to achieve an optimal and more tax effective model on a domestic, regional or global level.
She is regularly called upon by clients to advise on international and domestic tax planning matters concerning in-bound investments to achieve an optimal and effective business model, tax structuring and integrations postmerger and acquisitions as well as negotiating tax incentive applications for foreign investments into Malaysia.

Asia Pacific tax authorities are actively seeking to reduce tax leakages, non-compliance, and what they perceive to be tax avoidance activities. To help you position your business for success in an era of ever-changing tax rules and intense scrutiny, our subject matter experts from across the region and globally will come together to examine key developments. We will discuss the impact of emerging trends and current issues on your business models and strategies, sharing practical tips on how you can maximize opportunities to achieve the best risk mitigation outcomes.

The Malaysian Finance Act 2020 introduced, among others, several legislative changes to the Malaysian Income Tax Act 1967 (ITA) in respect of transfer pricing. Notably, a penalty provision was introduced. Effective 1 January 2021, taxpayers (where applicable) who fail to furnish transfer pricing documentation (TPD) upon the Malaysian Inland Revenue Board’s (MIRB’s) request will be subject to a fine ranging from RM 20,000 to RM 100,000 and / or imprisonment.

Consistent with this, the MIRB has also revised the Transfer Pricing Guidelines 2012 to reduce the time given to taxpayers to furnish their TPD from 30 days to 14 days.

The pandemic-afflicted economic distress has given rise to significant uncertainty and potentially an increase in tax audits. Malaysia has had advance pricing arrangement (“APA”) rules since 2012. APAs provide certainty in terms of transfer pricing risk management on a prospective basis.

Recently, the Malaysian Inland Revenue Board (“MIRB”) has issued a set of guidance in the form of frequently asked questions (“FAQ”) with respect to the treatment of APAs in the COVID-19 pandemic landscape. We are pleased to share the key takeaways from the FAQ on APA Treatment below.

The COVID-19 outbreak has led many countries to implement border controls as a temporary measure to curb infections, and many employers find their employees working from home or in locations outside the jurisdictions where employers typically operate or are located. International travel restrictions affect Boards of Directors and employees of…