International Bar Association. Tax Committee National Reporters. Recent Developments in Taxation. Malaysia. Irene Yong. Shearn Delamore & Co.
|
|
- Alan Sullivan
- 5 years ago
- Views:
Transcription
1 International Bar Association Tax Committee National Reporters Recent Developments in Taxation Malaysia Irene Yong Shearn Delamore & Co. [Draft covers developments in the period since June 2016]
2 1. RECENT HIGHLIGHTS 1.1 Foreign Account Tax Compliance Act ( FATCA ) Agreement in principle was reached with the US on the Malaysia-US Intergovernmental Agreement on FATCA ( IGA ) on 30 June 2014 but the IGA is yet to be signed. A draft of the Guidance Notes on the IGA was issued by the Inland Revenue Board ( IRB ) and revised as at 11 September Under the IGA, Reporting Malaysia-based Financial Institutions must identify and report US Reportable Accounts, as well as, payments made to certain Nonparticipating Financial Institutions (all capitalised terms as defined under the IGA), such information to be submitted to the IRB by 30 June of the year following the end of the relevant reporting year. Pending the execution of the IGA, the requirement to submit the information for 2014, 2015 and 2016 has been deferred (tentatively) to 30 June Common Reporting Standard (CRS) Pursuant to the Income Tax (Automatic Exchange of Financial Account Information) Rules 2016, which came into operation on 1 January 2017, Financial Institutions ( FIs ) which are resident in Malaysia (excluding branches located outside Malaysia) and any branch of an FI that is not resident in Malaysia if that branch is located in Malaysia, must report information regarding certain accounts of non-residents and follow related due diligence procedures, consistent with, amongst others, the Organisation for Economic Co-operation and Development s ( OECD s ) Common Reporting Standard. An information return is to be furnished to the IRB in respect of calendar year 2017 and subsequent calendar years by 30 June annually, commencing June Country-by-Country Reporting ( CBCR ) The Income Tax (Country-by-Country Reporting) Rules 2016 ( Rules ) came into operation on 1 January 2017 and apply to a multinational corporation group ( MNC Group ) where: (a) any of its constituent entities have any cross-border transactions with its other constituent entities; (b) the total consolidated group revenue in the financial year preceding the reporting financial year is at least RM3 billion (approximately US$700 million); (c) its ultimate holding company is incorporated under the Companies Act 1965 or under any written law and resident in Malaysia; and (d) its constituent entities are incorporated or registered under the Companies Act 1965 or under any written law or under the laws of a territory outside Malaysia and resident in Malaysia. Pursuant thereto, CBCRs are to be filed annually within 12 months after the last day of the reporting financial year by the ultimate holding company or surrogate holding company, each as defined, of the MNC Group that is resident in Malaysia. The CBCR 2
3 must contain aggregate information relating to the amount of revenue, profit or loss before income tax, income tax paid or accrued, stated capital, accumulated earnings, number of employees and tangible assets other than cash/cash equivalents with regard to each jurisdiction in which the MNC Group operates, and identification of each constituent entity of the MNC Group setting out the jurisdiction of tax residence, nature of the main business activity etc. 1.4 New penalty provisions for non-compliance With effect from 17 January 2017, failure to furnish a CBCR may be tantamount to an offence under a new Section 112A of the Income Tax Act 1967 ( ITA ), and the person may be liable to a fine of not less than RM20,000/- (approximately US$4600) and not more than RM100,000/- (approximately US$23000) or to imprisonment for a maximum term of 6 months or both. The accused bears the burden of proving that the CBCR has been furnished. Similar sanctions apply from 17 January 2017 under Sections 113A and 119B of the ITA respectively: (a) for making an incorrect return, information return or report or for giving any incorrect information relating to the foregoing, unless the person satisfies the court that the incorrect return, information etc was made/given in good faith; or (b) for non-compliance with the rules made on mutual administrative assistance. Where a person has been convicted for any of the offences under Sections 112A or 119B of the ITA, the court may further order that the relevant provisions of the rules be complied with, within a specified period. 1.5 Withholding Tax Widening of Scope of Withholding tax Royalty as defined, which is paid or credited to any non-resident is one of the classes of income subject to withholding tax, where it is derived/deemed derived from Malaysia. With effect from 17 January 2017, this definition has been broadened to include, amongst others, any sums paid as consideration for, or derived from: the use of or the right to use any software; the reception of or the right to receive, visual images, sound or both, transmitted to the public by satellite or cable, fibre optic or similar technology; the use of or the right to use, any visual images, sounds or both, in connection with television or radio broadcasting transmitted by satellite or cable, fibre optic or similar technology. 3
4 Remuneration or other income for services performed or rendered in Malaysia by a public entertainer are subject to withholding tax on payments made to a non-resident. With effect from 17 January 2017, the definition of public entertainer has been broadened and currently includes comperes, models, lecturers, speakers, sportspersons, artistes and any individual who uses his intellectual, artistic, musical, personal or physical skills in connection with any purpose through live, print, electronic, satellite, cable, fibre optic and other medium Derivation of Special Classes of Income Amounts paid in consideration of technical advice, assistance or services rendered in connection with technical management or administration of any scientific, industrial or commercial undertaking, venture, project or scheme which are performed outside Malaysia would be subject to withholding tax, with effect from 17 January Previously, only technical advice, assistance or services performed within Malaysia were subject to withholding tax. This has widened the scope of withholding tax. 1.6 Free Zones and Goods and Services Tax ( GST ) GST was implemented in Malaysia with effect from 1 April 2015, replacing the previous sales tax and service tax regime (since abolished). Certain areas in Malaysia have been designated as free zones under the Free Zones Act 1990 whereby a free zone is deemed to be a place outside Malaysia. Accordingly, goods may be brought into, produced, manufactured or provided in a free zone without payment of any customs duty and excise duty. For GST purposes, Malaysia excludes free zones and generally, no GST applies to the importation of goods into a free zone. With effect from 1 January 2017, no GST shall be charged on any supply of taxable goods made within or between free zones. However, GST is chargeable if goods are removed from one free zone to another through Malaysia or from a free zone to Malaysia. 1.7 Case Law Developments United Malacca Berhad ( UMB ) UMB, a Malaysian company carrying on the business of cultivation of oil palm and investment holding appealed before the Special Commissioners of Income Tax ( SCIT ) following the position taken by the IRB that the late payment charges received by UMB on the additional compensation for the compulsory acquisition of UMB s lands paid to UMB, as well as the retrenchment benefits which were reimbursed to UMB, should be subject to tax under the ITA. Penalties were also imposed by the IRB. The SCIT allowed the UMB s tax appeal in full. IRB lodged an appeal to the High Court. The High Court dismissed the IRB s appeal and affirmed the SCIT s decision and, in addition, granted costs to UMB. There is no further appeal to the Court of Appeal. 4
5 1.7.2 Maximum Vista Sdn Bhd ( MVSB ) The IRB disallowed the deduction of the annual discount expenses incurred by MVSB, a Malaysian investment holding company, on certain bonds issued by MVSB against the dividends received by MVSB. The SCIT, by a majority, allowed MVSB s tax appeal on the deductibility of the discount expenses on approximately 99.7% of MVSB s claim. The IRB then lodged an appeal to the High Court and MVSB also cross-appealed on the 0.3%. The case was concluded with a settlement Bandar Nusajaya Development Sdn Bhd The taxpayer was involved in developing Iskandar Malaysia and took a loan from its holding company at 5% interest rate + 7% premium rate. Rates were later revised down. From years of assessment 2003 to 2005, the taxpayer claimed tax deductions on the premium amount of RM222 million against business income (of RM40 million) and nonbusiness interest income (of RM181 million). When rates were revised, the taxpayer brought to tax RM40 million under Section 30(4) of the ITA but did not add back the rest. The IRB brought to tax RM181 million and raised a notice of additional assessment for RM50 million in additional taxes and imposed penalties of RM22 million for the year of assessment 2006 (collectively the Sum ). In 2014, the taxpayer filed a judicial review application before the High Court. Subsequently, the case was heard before the apex court, i.e. Federal Court, in which the taxpayer lost. It was thereafter reported in the press that the Federal Court had held that the taxpayer should have followed the appeal procedure and have the case heard before the SCIT by filing a notice of appeal (i.e. Form Q) under Section 99 of the ITA instead of filing a judicial review application. The Federal Court ordered the taxpayer to pay the Sum to the IRB. This seems to suggest that judicial review is not an alternative or automatic substitute for the Form Q procedure. 2. FUTURE DEVELOPMENTS 2.1 Tourism Tax Recently, the Tourism Tax Bill 2017 was tabled and passed in the Malaysian Parliament to levy a tourism tax on tourists who stay at accommodation premises (as per Section 2(1) of the Tourism Industry Act 1992), regardless of whether he is a Malaysian national or otherwise. The rate of the tourism tax is yet to be fixed. The operator of the accommodation premises is required to register with the Royal Malaysian Customs Department and collect the tax _1 5
CORPORATE TAX. Finance (No. 2) Bill 2017 Highlights 2
7 November 27 Finance (No. 2) Bill 27 Highlights 2 CORPORATE TAX Notification of Change in Accounting Period Currently, there is no provision in the Income Tax Act 967 ( the Act ) requiring a company,
More informationFinance 1 FINANCE BILL 2016
Finance 1 FINANCE BILL 2016 ARRANGEMENT OF CLAUSES Chapter I PRELIMINARY Clause 1. Short title 2. Amendment of Acts Chapter II AMENDMENTS TO THE INCOME TAX ACT 1967 3. Commencement of amendments to the
More information2017 MALAYSIAN BUDGET HIGHLIGHTS
2017 MALAYSIAN BUDGET HIGHLIGHTS The 2017 Budget was announced on Friday 21 October 2016 against the background of a challenging economic environment. The Budget theme of Ensuring Unity and Economic Growth,
More informationWithholding tax Deloitte Tax Services Sdn Bhd
Malaysian Dutch Business Council (MDBC) Burning International Tax Issues 3 April 2017 Withholding tax WHT - Introduction Imposed on non-residents deriving income from Malaysia. The payer is responsible
More informationJOINT MEMORANDUM ON ISSUES ARISING FROM 2017 BUDGET SPEECH & FINANCE BILL 2016 Date: 29 November 2016 Prepared by: Chartered Tax Institute of Malaysia; Malaysian Institute of Accountants; The Malaysian
More information2017 BUDGET HIGHLIGHTS (INCORPORATING FINANCE BILL 2016)
Proposal 1 Review of corporate income tax for SME 2 Reduction of corporate income tax rate based on the increase in chargeable business income Description Currently, for all SMEs the tax rate on chargeable
More information32 nd Annual Asia Pacific Tax Conference 10 & 11 November 2016 JW Marriott Hong Kong
32 nd Annual Asia Pacific Tax Conference 10 & 11 November 2016 JW Marriott Hong Kong 2016 Asia Pacific Tax Update Malaysia 1. Highlights of Budget 2017 The Prime Minister and Minister of Finance, YAB Dato'
More informationDeloitte Tax Max The 44 th Series #ReadyMalaysia2019: A refreshed landscape. Tuesday, 27 November 2018 l One World Hotel
Deloitte Tax Max The 44 th Series #ReadyMalaysia2019: A refreshed landscape Tuesday, 27 November 2018 l One World Hotel Navigating the transfer pricing and international tax landscape confidently Theresa
More information2014 Budget Highlights
October 2013 (Special Edition No. 2) Hyperlinks Advent Consulting Group Inland Revenue Board 2014 Budget Highlights Further to our Tax Flash October 2013 (Special Edition) and with the issuance of Finance
More information2017 Basic tax information in Malaysia
2017 Basic tax information in Malaysia INCOME TAX Direct taxation in Malaysia is based on the unitary system and the basis of taxation is territorial in nature. ly income that is accrued or derived from
More informationFilm Financing and Television Programming: A Taxation Guide
Film Financing and Television 1 Film Financing and Television Now in its seventh edition, KPMG LLP s ( KPMG ) Film Financing and Television (the Guide ) is a fundamental resource for film and television
More informationBy : NOR AZIZAN ADNAN NON RESIDENT BRANCH INLAND REVENUE BOARD OF MALAYSIA TAXATION OF NON RESIDENT PERSONS IN MALAYSIA
By : NOR AZIZAN ADNAN NON RESIDENT BRANCH INLAND REVENUE BOARD OF MALAYSIA 1 A NON RESIDENT PERSON (includes an individual and a corporation) SHALL BE CHARGED TO TAX ON INCOME ACCRUING IN OR DERIVED FROM
More informationThe Inland Revenue Board (IRB) has recently uploaded the new Form CP58 and the Guide Notes on Filling Out Form CP58 [Pin.1/2013] on its website.
RYTA TAXATION SERVICES SDN. BHD. (Company No. 70004-T) Tax Update Issue 4, April 2013 Statement of Monetary and Non-Monetary Incentive Payment to An Agent, Dealer or Distributor Pursuant to Section 83A
More informationTourism tax. EY Tax Alert. I. Date of coming into operation II. Tourism Tax Regulations 2017
Special Edition August 2017 - Issue 05 EY Tax Alert Tourism tax I. Date of coming into operation II. Tourism Tax Regulations 2017 Gazette Order regarding the effective date of coming into operation of
More informationCONSOLIDATED TO 1 DECEMBER 2014 LAWS OF SEYCHELLES
CONSOLIDATED TO 1 DECEMBER 2014 LAWS OF SEYCHELLES VALUE ADDED TAX ACT [1st January, 2013] Act 35of 2010 Act 3 of 2012 Act 13 of 2012 S.I. 62 of 2012 S.I. 65 of 2012 S.I. 33 of 2013 S.I. 34 of 2013 S.I.
More informationDouble Taxation Avoidance Agreement between Thailand and New Zealand
Double Taxation Avoidance Agreement between Thailand and New Zealand Completed on October 22, 1998 This document was downloaded from ASEAN Briefing (www.aseanbriefing.com) and was compiled by the tax experts
More informationASQ Basic tax information in Malaysia
ASQ 2016 Basic tax information in Malaysia INCOME TAX Direct taxation in Malaysia is based on the unitary system and the basis of taxation is territorial in nature. Only income that is accrued or derived
More informationLegal Perspective: Analysis of recent Director General s Decisions & Guidelines. Yuvaraj Sugapathy 19 May 2016
Legal Perspective: Analysis of recent Director General s Decisions & Guidelines Yuvaraj Sugapathy 19 May 2016 Agenda 1. Sources of Law 2. Primary Legislation vs Subsidiary Legislation 3. DG s Decisions
More informationChapter 10: Tax Planning
Chapter 10 Tax Planning Chapter Objectives Students must be able to: Explain the Scope of Charge to Malaysian Taxation Explain the Tax Treatment of Remittance Income Explain the Persons Chargeable to Tax
More informationIRAS e-tax Guide. Country-by-Country Reporting
IRAS e-tax Guide Country-by-Country Reporting Published by Inland Revenue Authority of Singapore Published on 10 October 2016 Disclaimers: IRAS shall not be responsible or held accountable in any way for
More informationTransfer Pricing ( TP ) and Advance Pricing Arrangements ( APAs ) Long Overdue Rules Given Retrospective Effect
MALAYSIA Tax Updates 2012/2013 ANAND RAJ anand@shearndelamore.com FOONG PUI CHI foongpuichi@shearndelamore.com PENNY WONG penny.wong@shearndelamore.com Transfer Pricing ( TP ) and Advance Pricing Arrangements
More informationPayments subject to withholding tax Generally, a person has to withhold tax when he makes payments of the following nature to a non-resident person:
RELEVANT TO ACCA QUALIFICATION PAPER F6 (SGP) Understanding withholding tax rules in Singapore In a nutshell, withholding tax is an efficient mechanism to collect corporate income tax from certain groups
More informationTax Update 18 October 2010
Tax Update 18 October 2010 PERSONAL TAX Relief for EPF & Life Insurance Existing EPF relief of maximum RM 6,000 is to be extended to include employees contributions and self-employed, contributed to the
More informationAdvancing Tax Reform* 2009/10 Tax Measures - Implementation Update
Taxation Services Client Newsletter * 2009/10 Tax Measures - Implementation Update In this Issue: Major reform of dividend taxation rules New dividend withholding tax requirements New withholding tax rules
More informationPROFESSIONAL EXAMINATIONS INTERMEDIATE LEVEL PERSONAL TAXATION. Date
CHARTERED TAX INSTITUTE OF MALAYSIA (225750 T) (Institut Percukaian Malaysia) PROFESSIONAL EXAMINATIONS INTERMEDIATE LEVEL PERSONAL TAXATION JUNE 2018 Student Registration No. Desk No. Date Examination
More informationIncome from Other Sources
Income from Other Sources Index 1. Section 11. Heads of income...262 2. Section.101. Geographical source of income...262 3. Section 15. Income from property...262 4. Section 112. Liability in respect of
More informationWITHHOLDING TAX IN IN MALAYSIA Understanding the Law and Practice
WITHHOLDING TAX IN IN MALAYSIA Understanding the Law and Practice Date Time Venue Fees : 19 April 2017 (Wednesday) : 9.00am to 5.00pm (registration starts from 8.00am) : Nusantara Ballroom II, Sheraton
More informationGlobal Transfer Pricing Review
GLOBAL TRANSFER PRICING SERVICES Global Transfer Pricing Review Malaysia kpmg.com TAX Malaysia KPMG observation Malaysia is currently in the eighth year since the official introduction of transfer pricing
More information9 AUGUST Clear Water Sanctuary Golf Management Case: Recognition Of Advance Payments
9 AUGUST 2016 Clear Water Sanctuary Golf Management Case: Recognition Of Advance Payments Sections 24(1)(b) and 24(1)(c) of the Income Tax Act 1967 (ITA) govern the recognition of income arising from the
More informationCanberra. (c) Commonwealth of Australia 1996
Agreement between Australia and the Czech Republic for the Avoidance of Double Taxation and the Prevention of Fiscal Evasion with respect to Taxes on Income (Canberra, 28 March 1995) Entry into force:
More informationAccount Opening Supplement - Tax Status
INVESTMENT MANAGEMENT 2016 Account Opening Supplement - Tax Status With the recent introduction of the OECD Common Reporting Standard ( CRS ) and U.S. Foreign Account Tax Compliance Act (FATCA), new information
More informationNewsletter October 2018
Tax Newsletter BEPS Series Kuala Lumpur Newsletter October 2018 In This Issue 1. What is BEPS? 2. BEPS Action 13 Transfer Pricing Documentation and Reporting 3. Malaysia Response and Implementation 4.
More informationGlobal Transfer Pricing Review kpmg.com/gtps
Global Transfer Pricing Review Czech Malaysia Republic kpmg.com/gtps TAX 2 Global Transfer Pricing Review Malaysia KPMG observation The Malaysian tax authority has been very active in monitoring taxpayer
More informationThe Income Tax and GST Appeal Processes. D.P. Naban, Senior Partner 2 November 2016
The Income Tax and GST Appeal Processes D.P. Naban, Senior Partner 2 November 2016 1 Agenda Income Tax Appeal Dispute Resolution Proceedings Special Commissioners of Income Tax High Court Judicial Review
More informationHONG KONG. 1. Introduction. Contact Information Henry Fung Candice Ng
HONG KONG Contact Information Henry Fung +852 2969 4054 hernyfung@pkf-hk.com Candice Ng +852 2969 4016 candiceng@pkf-hk.com 1. Introduction 1.1. Legal context Currently, the Hong Kong Inland Revenue Ordinance
More informationT. P. Ostwal & Associates (Regd.) Key Budget Proposal Budget 2012 CHARTERED ACCOUNTANTS
IMPORTANT AMENDMENTS & MAJOR DIRECT TAX PROPOSALS IN FINANCE BILL, 2012 CORPORATE TAX No change in the head corporate tax. Extension of sunset date for tax holiday for power sector to 2013; Initial depreciation
More informationSeminar on industry wise analysis of indirect tax issues Media, Entertainment & Software
Seminar on industry wise analysis of indirect tax issues Media, Entertainment & Software 8 February 2014 Media & Entertainment Page 2 Basic Understanding Page 3 Basic Understanding The major segments of
More informationGQG GLOBAL UCITS ICAV
GQG GLOBAL UCITS ICAV An open-ended umbrella ICAV with segregated liability between its Funds registered under the laws of Ireland authorised and regulated by the Central Bank of Ireland pursuant to the
More informationTAX REFORM TO IMPROVE COMPLIANCE
TAX REFORM TO IMPROVE COMPLIANCE MALAYSIA DATUK SABIN SAMITAH Deputy CEO, Inland Revenue Board of Malaysia (IRBM) The Seventh IMF-Japan High-Level Tax Conference For Asian Countries 5-7 April 2016 Tokyo
More informationAGREEMENT BETWEEN THE GOVERNMENT OF MALAYSIA AND THE GOVERNMENT OF THE LEBANESE REPUBLIC FOR THE AVOIDANCE OF DOUBLE TAXATION AND
AGREEMENT BETWEEN THE GOVERNMENT OF MALAYSIA AND THE GOVERNMENT OF THE LEBANESE REPUBLIC FOR THE AVOIDANCE OF DOUBLE TAXATION AND THE PREVENTION OF FISCAL EVASION WITH RESPECT TO TAXES ON INCOME The Government
More information1. GENERAL 2 2. SUMMARY OF THE PRINCIPAL CHANGES INCOME TAX (AMENDMENT) ACT COMMENTARY ON THE INCOME TAX 6-9 (AMENDMENT) ACT 2001
CONTENTS PAGE 1. GENERAL 2 2. SUMMARY OF THE PRINCIPAL CHANGES INCOME TAX (AMENDMENT) ACT 2001 3-4 3. COMMENTARY ON THE INCOME TAX 6-9 (AMENDMENT) ACT 2001 3. OTHER MATTERS 10-11 4. ZAMBIA REVENUE AUTHORITY
More informationStructuring Investments into Malaysia Tax Issues
Structuring Investments into Malaysia Tax Issues December 2011 Dr. Veerinderjeet Singh 2 Agenda 3 Overview of Malaysia Corporate Tax Tax Incentives Other Taxes Example: Malaysia as a Holding Company Labuan
More information1. Codifies transfer pricing rules, relief and provides for advance pricing arrangement (APA) regime to cater for unilateral,
JANUARY 2018 WWW.BDO.COM.HK HONG KONG TAX HONG KONG INTRODUCES TAX BILL TO IMPLEMENT MINIMUM STANDARDS OF THE BASE EROSION AND PROFIT SHIFTING TRANSFER PRICING REGULATORY REGIME AND DOCUMENTATION REQUIREMENTS
More informationPaper P6 (MYS) Advanced Taxation (Malaysia) March/June 2017 Sample Questions. Professional Level Options Module
Professional Level Options Module Advanced Taxation (Malaysia) March/June 2017 Sample Questions Time allowed: 3 hours and 15 minutes This question paper is divided into two sections: Section A BOTH questions
More informationM K LAND HOLDINGS BERHAD (INCORPORATED IN MALAYSIA) H
CONDENSED CONSOLIDATED STATEMENT OF COMPREHENSIVE INCOME INDIVIDUAL QUARTER (Q4) CUMULATIVE QUARTER (12 Mths) CURRENT YEAR QUARTER PRECEDING YEAR CORRESPONDING QUARTER CUMULATIVE CURRENT YEAR CUMULATIVE
More informationAGREEMENT BETWEEN THE GOVERNMENT OF THE REPUBLIC OF SOUTH AFRICA AND THE GOVERNMENT OF THE KINGDOM OF LESOTHO FOR THE AVOIDANCE OF DOUBLE TAXATION AND
AGREEMENT BETWEEN THE GOVERNMENT OF THE REPUBLIC OF SOUTH AFRICA AND THE GOVERNMENT OF THE KINGDOM OF LESOTHO FOR THE AVOIDANCE OF DOUBLE TAXATION AND THE PREVENTION OF FISCAL EVASION WITH RESPECT TO TAXES
More informationProfessional Level Options Module, Paper P6 (MYS)
Answers Professional Level Options Module, Paper P6 (MYS) Advanced Taxation (Malaysia) September/December 2016 Sample Answers 1 Letter to Smart Incorporated Tax Firm Any Street 50000 Kuala Lumpur Malaysia
More informationPROFESSIONAL EXAMINATIONS ADVANCE TAXATION 2 DECEMBER Date
CHARTERED TAX INSTITUTE OF MALAYSIA (225750 T) (Institut Percukaian Malaysia) PROFESSIONAL EXAMINATIONS FINAL LEVEL ADVANCE TAXATION 2 DECEMBER 2015 Student Registration No. Desk No. Date Examination Centre
More informationMALAYSIA GLOBAL GUIDE TO M&A TAX: 2017 EDITION
MALAYSIA 1 MALAYSIA INTERNATIONAL DEVELOPMENTS 1. WHAT ARE RECENT TAX DEVELOPMENTS IN YOUR COUNTRY WHICH ARE RELEVANT FOR M&A DEALS AND PRIVATE EQUITY? Please see question 2 below. 2. WHAT IS THE GENERAL
More informationNovember 2010 Hyperlinks
November 2010 Hyperlinks Advent Consulting Group Inland Revenue Board Preferential Tax Treatment for Knowledge Workers in Iskandar Malaysia Following the 2010 Budget announcement, the Income Tax (Determination
More informationInternational Tax Argentina Highlights 2018
International Tax Argentina Highlights 2018 Investment basics: Currency Argentine Peso (ARS) Foreign exchange control Argentina operates a limited foreign exchange control regime. The transfer of funds
More informationMALAYSIA: BUDGET 2017 HIGHLIGHTS
MALAYSIA: BUDGET 2017 HIGHLIGHTS (Including updates on significant tax amendments proposed in the Finance Bill 2016) OCTOBER 2016 EXECUTIVE SUMMARY The 2017 Budget, tabled in Parliament on 21 October 2016
More informationContents. Page 2 Withholding tax in Singapore 2015 edition.
Page 2 Withholding tax in Singapore 2015 edition. Contents Concept of withholding tax... 4 Scope of taxation... 5 System of taxation... 5 Income subject to withholding tax... 5 Non compliance... 6 Importance
More informationForeign Account Tax Compliance Act (FATCA) and Common Reporting Standards (CRS) Self-Certification Form for Entities
Foreign Account Tax Compliance Act (FATCA) and Common Reporting Standards (CRS) Self-Certification Form for Entities This is a self-certification form ("Certification Form") that you will need to complete
More informationFSI Tax Update Automatic Exchange of Financial Account Information: No Longer When but with Which Countries?
FSI Tax Update Automatic Exchange of Financial Account Information: No Longer When but with Which Countries? By Chee Pei Pei and Mohd Fariz Mohd Faruk Background Common Reporting Standard ( CRS ) on Automatic
More informationFjji Tax Profile. Produced in conjunction with the KPMG Asia Pacific Tax Centre. Updated: June 2015
Fjji Tax Profile Produced in conjunction with the KPMG Asia Pacific Tax Centre Updated: June 2015 Contents 1 Corporate Income Tax 1 2 International Treaties for the Avoidance of Double Taxation 6 3 Indirect
More informationSwaziland Revenue Authority DOMESTIC TAXES DEPARTMENT
Swaziland Revenue Authority DOMESTIC TAXES DEPARTMENT STAMP IT 12 P.O. Box 5628 Mbabane, Swaziland Tel: (+268) 2406-4000 Fax: (+268) 2406 4001 E-mail: info@sra.org.sz Website: www.sra.org.sz RETURN OF
More informationTax controversy and Tax amnesty 2016
Tax Thought Leadership Series Tax controversy and Tax amnesty 2016 Tuesday, 27 September 2016 Hilton Kuching GST audit and investigation Speaker: Bernard Yap, Partner, Indirect Tax Ernst & Young Tax Consultants
More informationHONG KONG BEPS AND NEW TRANSFER PRICING LAW
10 July 2018 HONG KONG BEPS AND NEW TRANSFER PRICING LAW Executive summary Hong Kong's Legislative Council on 4 July 2018 passed the Inland Revenue (Amendment) (No. 6) Bill 2017), which became effective
More informationChairman Camp s Discussion Draft of Tax Reform Act of 2014 and President Obama s Fiscal Year 2015 Revenue Proposals
Chairman Camp s Discussion Draft of Tax Reform Act of 2014 and President Obama s Fiscal Year 2015 Proposals Relating to International Taxation SUMMARY On February 26, 2014, Ways and Means Committee Chairman
More informationFinance 1 LAWS OF MALAYSIA. Act 702 FINANCE ACT 2010
Finance 1 LAWS OF MALAYSIA Act 702 FINANCE ACT 2010 2 Date of Royal Assent...... 6 January 2010 Date of publication in the Gazette......... 14 January 2010 Publisher s Copyright C PERCETAKAN NASIONAL MALAYSIA
More informationFATCA: Impact on Cayman Islands Entities
FATCA: Impact on Cayman Islands Entities Preface This publication provides a brief overview of the impact on entities incorporated in the Cayman Islands of the foreign account tax compliance provisions
More informationTAX STATUS DECLARATION FORM
SAVINGS INVESTMENTS LIFE INSURANCE TAX STATUS DECLARATION FORM ENTITIES Purpose Financial Institutions in Ireland are required under legislation to seek answers to questions for purposes of identifying
More informationDAY 2: WEDNESDAY, 26 JULY 2017
1 DAY 2: WEDNESDAY, 26 JULY 2017 TAXATION OF ROYALTIES, SERVICES AND WITHHOLDING TAX ISSUES DIFFERENT PERSPECTIVES Speaker: Hazlina Hussain Director Dispute Resolution & the Board Secretariat Department
More informationMalaysian Budget Member Firm of CAS International
Malaysian Budget 2010 Member Firm of CAS International Contents Introduction Pages A. Personal Tax 1. Reduction in individual tax rate 2. Increase in Personal Relief 3. Individual tax relief on broadband
More informationMAURITIUS BROADCASTING CORPORATION ACT MAURITIUS BROADCASTING CORPORATION ACT. Revised Laws of Mauritius. Act 22 of October 1982
Revised Laws of Mauritius MAURITIUS BROADCASTING CORPORATION ACT Act 22 of 1982 9 October 1982 ARRANGEMENT OF SECTIONS SECTION 1. Short title 2. Interpretation 3. Establishment of Corporation 4. Objects
More informationTransfer Pricing Documentation
2018 Transfer Pricing Documentation BRIEF ON FURTHER AMENDMENTS MADE THROUGH S.R.O. 144(I)/2018 DATED FEBRUARY 9, 2018 ON THE DOCUMENTATION AND COUNTRY-BY-COUNTRY REPORTING REQUIREMENTS FOREWORD This document
More informationCorporate Income Tax. Withholding Tax. Basis of Taxation. Exemptions. Corporate Tax Rebate (Temporary) Residence. Dividends 0 15*
SINGAPORE TAX FACTS Corporate Income Tax Basis of Taxation Singapore taxes businesses on a preceding year basis on Singapore-sourced income and on foreign-sourced income remitted into Singapore. Whether
More informationMUTUAL ADMINISTRATIVE ASSISTANCE IN TAX MATTERS (AMENDMENT) ACT 2017 ARRANGEMENT OF SECTIONS
BELIZE: MUTUAL ADMINISTRATIVE ASSISTANCE IN TAX MATTERS (AMENDMENT) ACT 2017 ARRANGEMENT OF SECTIONS 1. Short title. 2. Insertion of new heading. 3. Amendment of section 2. 4. Insertion of new section
More informationSales Tax, Service Tax and Price Control & Anti-Profiteering Latest Updates!
INDIRECT TAX Sales Tax, Service Tax and Price Control & Anti-Profiteering Latest Updates! 21 August 2018 One World Hotel, Petaling Jaya Extra! Dialogue with Inland Revenue Board on Tax Audit and Investigation
More informationLABUAN OFFSHORE BUSINESS ACTIVITY TAX ACT 1990 PART II CHARGEABILITY TO TAX. Tax Based on Return. Tax Charged upon Election
LABUAN OFFSHORE BUSINESS ACTIVITY TAX ACT 1990 1. Short title and commencement 2. Interpretation ARRANGEMENT OF SECTIONS PART I PRELIMINARY PART II CHARGEABILITY TO TAX Scope of Charge 3. Offshore business
More informationThe Income Tax Order 12 of 1975
The Income Tax Order 12 of 1975 (Title amended A.11/1985.) Date of Commencement: 1st July, 1975. Date of Assent: 8th July, 1975. Arrangement of Sections PART I 1. Short title. 2. Interpretation. 3. Appointment
More informationJOINT MEMORANDUM ON ISSUES ARISING FROM 2016 BUDGET AND JOINT MEMORANDUM ON ISSUES ARISING FROM 2016 BUDGET AND FINANCE BILL 2015 & OTHER TECHNICAL MATTERS Prepared by: Date: 19 November 2015 Chartered
More informationInternational Tax Canada Highlights 2018
International Tax Canada Highlights 2018 Investment basics: Currency Canadian Dollar (CAD) Foreign exchange control None. No restrictions are imposed on borrowing from abroad; the repatriation of capital;
More informationThai Tax 2011 Booklet
www.pwc.com/th Thai Tax 2011 Booklet This document has been prepared for general guidance on matters of interest only, and does not constitute professional advice. You should not act upon the information
More informationExchange of information on Tax Rulings
Exchange of information on Tax Rulings 24 November 2016 Jean-Michel Hamelle Partner Tax and Accounting Agenda 2 Exchange of Information on Tax Rulings OECD BEPS Action 5 EU Directive 2015/2376/EU Luxembourg
More informationValue Added Tax (Amendment) Act No. 6 Of 2003
Value Added Tax (Amendment) Act No. 6 Of 2003 An Act to amend the Value Added Tax Act 2001 1 in order to make provision for zero ratings and to provide more comprehensively on electronic and cross border
More informationANTIGUA AND BARBUDA - TAX STRUCTURE
ANTIGUA AND BARBUDA - TAX STRUCTURE Tax Type Tax Base Tax Rate Method of Application Exemptions and Deductions Travel Tax Entertainment Tax A tax payable on every ticket issued for travel originating in
More informationCONVENTION BETWEEN IRELAND AND THE KINGDOM OF MOROCCO FOR THE AVOIDANCE OF DOUBLE TAXATION AND THE PREVENTION OF FISCAL EVASION
CONVENTION BETWEEN IRELAND AND THE KINGDOM OF MOROCCO FOR THE AVOIDANCE OF DOUBLE TAXATION AND THE PREVENTION OF FISCAL EVASION WITH RESPECT TO TAXES ON INCOME The Government of Ireland and the Government
More informationCONVENTION. between THE GOVERNMENT OF BARBADOS. and THE GOVERNMENT OF THE REPUBLIC OF GHANA
CONVENTION between THE GOVERNMENT OF BARBADOS and THE GOVERNMENT OF THE REPUBLIC OF GHANA FOR THE AVOIDANCE OF DOUBLE TAXATION AND THE PREVENTION OF FISCAL EVASION WITH RESPECT TO TAXES ON INCOME AND ON
More informationDouble Taxation Avoidance Agreement between Thailand and Hong Kong
Double Taxation Avoidance Agreement between Thailand and Hong Kong This document was downloaded from ASEAN Briefing (www.aseanbriefing.com) and was compiled by the tax experts at Dezan Shira & Associates
More informationLegal Supplement Part C to the Trinidad and Tobago Gazette, Vol. 55, No. 109, 22nd September, 2016
Legal Supplement Part C to the Trinidad and Tobago Gazette, Vol. 55, No. 109, 22nd September, 2016 No. 11 of 2016 First Session Eleventh Parliament Republic of Trinidad and Tobago HOUSE OF REPRESENTATIVES
More informationGibraltar Tax Facts 2010/2011
www.pwc.gi Gibraltar Tax Facts This publication is a practical and easyto-follow guide to the Gibraltar tax system. 2010/2011 01 October 2010 This booklet is also available online at www.pwc.gi A list
More informationRevisiting the Public Ruling Relating to Withholding Tax for Better Compliance
Available online at www.icas.my International Conference on Accounting Studies (ICAS) 2016 Revisiting the Public Ruling Relating to Withholding Tax for Better Compliance Hazlina Hussain *, Nor Aziah Abdul
More informationCHARTERED TAX INSTITUTE OF MALAYSIA ( T) (Institut Percukaian Malaysia) PROFESSIONAL EXAMINATIONS. Date
CHARTERED TAX INSTITUTE OF MALAYSIA (225750 T) (Institut Percukaian Malaysia) PROFESSIONAL EXAMINATIONS FINAL LEVEL REVENUE LAW DECEMBER 2018 Student Registration No. Desk No. Date Examination Centre Time
More informationPwC Alert. Foreign Account Tax Compliance Act (FATCA) The US federal law affecting local financial institutions
Issue 122 January 2015 PP 9741/10/2012 (031262) PwC Alert Foreign Account Tax Compliance Act (FATCA) The US federal law affecting local financial institutions Page 2 About FATCA Page 7 Impact to Malaysia
More information7148/16 HG/NT/kp,vm DGG 2B
Council of the European Union Brussels, 11 May 2016 (OR. en) Interinstitutional File: 2016/0010 (CNS) 7148/16 FISC 39 ECOFIN 231 LEGISLATIVE ACTS AND OTHER INSTRUMENTS Subject: COUNCIL DIRECTIVE amending
More informationAGREEMENT BETWEEN THE GOVERNMENT OF THE KINGDOM OF THAILAND AND THE GOVERNMENT OF THE HONG KONG SPECIAL ADMINISTRATIVE
AGREEMENT BETWEEN THE GOVERNMENT OF THE KINGDOM OF THAILAND AND THE GOVERNMENT OF THE HONG KONG SPECIAL ADMINISTRATIVE REGION OF THE PEOPLE S REPUBLIC OF CHINA FOR THE AVOIDANCE OF DOUBLE TAXATION AND
More informationStay current. Be tax savvy
www.pwc.com/my Stay current. Be tax savvy TaXavvy March 2014 Issue 2/2014 Inside this issue Tax Laws Amendment of Petroleum Income Tax Gazette Orders Stamp duty exemption for Small and Medium Enterprises
More informationENTITY SELF CERTIFICATION FORM. Entity Participants
ENTITY SELF CERTIFICATION FORM Entity Participants Tax regulations may require Nasdaq Clearing AB to collect certain information about each account holder s tax residency and tax classification for the
More informationAGREEMENT BETWEEN THE KINGDOM OF BELGIUM AND THE SULTANATE OF OMAN FOR THE AVOIDANCE OF DOUBLE TAXATION AND THE PREVENTION OF FISCAL EVASION
AGREEMENT BETWEEN THE KINGDOM OF BELGIUM AND THE SULTANATE OF OMAN FOR THE AVOIDANCE OF DOUBLE TAXATION AND THE PREVENTION OF FISCAL EVASION WITH RESPECT TO TAXES ON INCOME AGREEMENT BETWEEN THE KINGDOM
More informationPlease provide the Account Holder s Status by ticking one of the following boxes. 1. (a) Financial Institution Investment Entity
Part 2 Entity Type Please provide the Account Holder s Status by ticking one of the following boxes. 1. (a) Financial Institution Investment Entity i. An Investment Entity located in a Non-Participating
More informationProfessional Level Options Module, Paper P6 (MYS)
Answers Professional Level Options Module, Paper P6 (MYS) Advanced Taxation (Malaysia) June 2008 Answers Note: All references to legislation or public rulings shown in square brackets are for information
More informationCHARTERED TAX INSTITUTE OF MALAYSIA ( T) (Institut Percukaian Malaysia) PROFESSIONAL EXAMINATIONS ADVANCE TAXATION 2. Date
CHARTERED TAX INSTITUTE OF MALAYSIA (225750 T) (Institut Percukaian Malaysia) PROFESSIONAL EXAMINATIONS FINAL LEVEL ADVANCE TAXATION 2 JUNE 2017 Student Registration No. Desk No. Date Examination Centre
More informationPaper P6 (MYS) Advanced Taxation (Malaysia) Friday 5 June Professional Level Options Module. The Association of Chartered Certified Accountants
Professional Level Options Module Advanced Taxation (Malaysia) Friday 5 June 2015 Time allowed Reading and planning: Writing: 15 minutes 3 hours This paper is divided into two sections: Section A BOTH
More informationFATCA: Impact on Mauritius Entities
FATCA: Impact on Mauritius Entities Foreword This publication provides a brief overview of the expected impact on entities resident in the Republic of Mauritius ( Mauritius ) of the foreign account tax
More informationGlobal Mobility Services: Taxation of International Assignees - Lesotho
www.pwc.com/globalmobility Global Mobility Services: Taxation of International Assignees - Lesotho Taxation issues & related matters for employers & employees 2018/19 Last Updated: June 2018 This document
More informationCountry by country (CbC) reporting reaches Indian shores. By Paresh Parekh, Partner, EY March 2, 2016
Country by country (CbC) reporting reaches Indian shores By aresh arekh, artner, EY March 2, 2016 Contents CbC reporting BES Action 13 - background Budget 2016 proposals Global overview age 2 BES - What
More informationFiji Tax Profile. Produced in conjunction with the KPMG Asia Pacific Tax Centre. Updated: October 2016
Fiji Tax Profile Produced in conjunction with the KPMG Asia Pacific Tax Centre Updated: October 2016 Contents 1 Corporate Income Tax 1 2 International Treaties for the Avoidance of Double Taxation 8 3
More informationINCOME TAX BILL, 2018
INCOME TAX BILL, 2018 ALERT ALGERIA BOTSWANA ETHIOPIA GUINEA KENYA MADAGASCAR MALAWI MAURITIUS MOROCCO MOZAMBIQUE NIGERIA RWANDA SUDAN TANZANIA UGANDA ZAMBIA REGIONAL OFFICE: UAE ASSOCIATE FIRM: SOUTH
More information