Tag: Cost plus mark up

A cost plus mark is a upmark up that is measured by reference to margins computed after the direct and indirect costs incurred by a supplier of property or services in a
transaction.

Malaysia vs Shell Services Asia Sdn Bhd, November 2019, High Court, Case No BA 25-68-08/2019

Malaysia vs Shell Services Asia Sdn Bhd, November 2019, High Court, Case No BA 25-68-08/2019

The principal activities of Shell Services Asia Sdn Bhd in Malaysia is to provide services to related companies within the Shell Group. The company is part of a contractual arrangement for the sharing of services and resources within the Shell Group as provided in a Cost Contribution Arrangement. The tax authorities conducted a transfer pricing audit, and based on the findings, issued a tax assessment for fiscal years 2011 to 2016, where the Cost Contribution Arrangement had been recharacterised as an intra-group services arrangement. The taxable income was adjusted by imposing a markup on the total costs of the company for fiscal years 2012, 2014, 2015 and 2016. Consequently, the company had to pay the additional taxes in the amount of: RM 3,474,978.44; RM 2,559,754.38; RM 7,096,984.69; RM 2,537,458.50; RM 15,669,176.01. The company did not agree with the proposal. The judgement by the High Court only relates to proceedings and no views is expressed regarding the tax assessment. Malaysia vs Shell_High_Court BA-25-68--08-2019 ... Continue to full case