Malaysia: Impact of COVID-19 on Advance Pricing Arrangements in Malaysia Malaysia has had advance pricing arrangement ("APA") rules since 2012. Recently, the Malaysian Inland Revenue Board has issued a set of guidance in the form of frequently asked questions with respect to the treatment of APAs in the COVID-19 pandemic landscape. 330 In brief 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 (“