Expenses transactions are consistently one of the highest-risk areas identified during tax audits conducted by LHDN. Unlike revenue, which is typically supported by external documentation, expenses often rely heavily on internal records, judgement, and classification decisions.
As a result, errors, misclassification, and unsupported claims are frequently detected during audits. In many cases, these issues are not due to intentional wrongdoing, but rather weak documentation practices, poor internal controls, or misunderstanding of tax rules (Inland Revenue Board of Malaysia, 2019; Messier, Glover, & Prawitt, 2017).
From an audit perspective, these weaknesses increase the likelihood of adjustments, additional tax assessments, and penalties. Understanding the common risk areas is therefore critical for businesses to identify potential exposure before an audit takes place (Malaysia, 1967; Inland Revenue Board of Malaysia, 2019).
Overstatement of expenses is one of the most common issues identified during tax audits. This occurs when taxpayers inflate the amount of expenses claimed, either through duplicate entries, exaggerated costs, or unsupported adjustments.
This risk often arises from weak accounting controls, lack of reconciliation, or intentional manipulation to reduce taxable income.
From an audit perspective, overstatement directly reduces reported profits and tax payable. When detected, LHDN will disallow the excess portion, resulting in additional tax assessments and potential penalties (Inland Revenue Board of Malaysia, 2019; Malaysia, 1967).
Example:
A business records the same supplier invoice more than once or includes estimated costs without proper supporting documentation.
Another frequent issue is the inclusion of personal or non-deductible expenses as business expenses. Under the “wholly and exclusively” principle, such expenses are not allowable for tax purposes (Malaysia, 1967).
This commonly occurs in owner-managed businesses where the separation between personal and business finances is not strictly maintained.
During a tax audit, these expenses are typically identified and fully disallowed. This not only increases taxable income but may also raise further scrutiny on other expense categories (Inland Revenue Board of Malaysia, 2019).
Example:
Personal travel, private vehicle costs, or household-related expenses recorded under company accounts.
The absence of adequate supporting documentation is a critical audit risk. Even where an expense is genuinely incurred, failure to provide sufficient evidence may result in the expense being disallowed.
This risk usually arises from poor record-keeping practices, lost documents, or reliance on informal transactions without proper invoicing.
From LHDN’s perspective, documentation is essential to verify the existence, accuracy, and business purpose of an expense. Without it, the claim cannot be substantiated (Inland Revenue Board of Malaysia, 2019; Malaysia, 1967).
Example:
Consultancy fees claimed without invoices, agreements, or proof of payment.
Expenses involving related parties carry an additional layer of risk, particularly where transactions are not conducted at arm’s length.
Without proper transfer pricing documentation, these transactions may be viewed as a mechanism to shift profits and reduce tax exposure.
During an audit, LHDN may challenge the pricing of such transactions and disallow any portion deemed excessive or not commercially justified (Inland Revenue Board of Malaysia, 2012; Inland Revenue Board of Malaysia, 2019).
Example:
Management fees paid to a related company without benchmarking or supporting transfer pricing analysis.
Double claiming occurs when the same expense is recorded more than once, either due to accounting errors or poor internal controls.
This typically arises from failure to reconcile records properly, especially where multiple systems or manual entries are involved.
From an audit perspective, double claiming results in an artificial increase in expenses and a reduction in taxable income. When identified, the duplicated portion will be disallowed (Inland Revenue Board of Malaysia, 2019; Malaysia, 1967).
Example:
An expense recorded based on both the supplier invoice and the payment record separately without proper reconciliation.
These common risks highlight the importance of maintaining strong internal controls, proper documentation, and clear expense classification.
From an audit standpoint, LHDN focuses not only on whether an expense exists, but whether it is properly supported, correctly classified, and fully compliant with tax legislation (Inland Revenue Board of Malaysia, 2019).
Failure to address these risks may result in significant tax adjustments, penalties, and increased scrutiny during future audits (Malaysia, 1967; Inland Revenue Board of Malaysia, 2019).