JULY 2015 ISSUE 7 ASEAN INVESTMENT & TAX NEWS NEWS

Transcription

1 JULY 2015 ISSUE 7 ASEAN INVESTMENT & TAX FEATURE ARTICLE READ MORE Page 2-3 READ MORE Page 3-8 FOREWORD Welcome readers to the seventh issue of BDO s ASEAN Investment & Tax News (AITN). This issue is especially dear to heart as it coincides with the pinnacle of BDO Malaysia s year-long 50 th Anniversary celebration, the Gala Dinner in July The Malaysian firm has certainly come a long way since it first opened its doors in August 1964 with only a handful of staff. The Firm now has over 1,000 staff led by more than 90 partners and directors from offices in Kuala Lumpur, Penang and Johor Bahru as well as through the regional operations in Brunei, Cambodia, Lao PDR, Myanmar and Vietnam. Certainly, this is a testament of the growth over the years which would not have been possible except for the tremendous commitment of its stakeholders including a formidable pool of partners and staff, effective regulators and supportive clients. In conjunction with BDO Malaysia s 50 th Anniversary, our feature article is focused on key developments in Corporate Tax incentives for Global or Regional Service Centres in Malaysia. We will take a look at the Malaysian Government s initiative to entice foreign corporations to set up their global or regional centres in the country. Meanwhile, our colleagues in Indonesia focuses on new government regulation on tax allowance facilities available for investments in certain industries and/or regions within the country that came into effect from 6 May Over in Thailand, the country s Prime Minister has delayed the new house and land tax citing the slowdown of the Thai economy and its potential negative impact on low income earners. The team in Vietnam will be sharing with us the new changes in legislation on property ownership whereby foreigners are allowed to own properties in the country. CONTENTS P1 FOREWORD P2 FEATURE ARTICLE u Malaysia: Key Developments in Corporate Tax Incentives For Global/Regional Service Centre In Malaysia P3 u Indonesia: New Regulation On Tax Allowance Facilities u New Changes In Legislation On Property Ownership In Vietnam u Myanmar: New Tax Law Of The Union And Competition Law 2015 u Delay Of New House And Land Tax In Thailand u Evolution of Singapore Foreign Income Tax Exemption Other updates include Myanmar s new Tax Law of the Union and Competition Law 2015 and Singapore s evolution of foreign income tax exemption. We certainly hope you find this issue of BDO s AITN informative and beneficial. Do feel free to contact any of our offices should you require more details or in-depth advice on the topics covered herein. May we take the opportunity to wish all who are observing the fasting month, a blessed Ramadhan. DATO GAN AH TEE DNS JP Regional Senior Partner BDO Asean Investment & Tax News_Rev7_30th JUNE '15.indd 1

2 2 ASEAN INVESTMENT & TAX FEATURE KEY DEVELOPMENTS IN CORPORATE TAX INCENTIVES FOR GLOBAL/REGIONAL SERVICE CENTRES IN MALAYSIA by David Lai Head of Tax Advisory, BDO Malaysia Tier Annual Spending (min) *Manpower (min) Countries Served (min) **Corporate tax rate (flat) enjoyed 1 RM10 million 50 high value jobs, including 5 key strategic/management positions 5 0% 2 RM5 million 30 high value jobs, including 4 key strategic/management positions 4 5% 3 RM3 million 15 high value jobs, including 3 key strategic/management positions 3 10% In line with the its initiative to entice foreign corporations to set up their global/ regional service centres in Malaysia, the Malaysian Government had previously introduced various fiscal incentives to enhance the attractiveness of Malaysia as a centre for these operations. Amongst these incentives are tax incentives awarded to companies providing key support operations to their related companies located within as well as outside Malaysia. Examples of these key support services include activities such as Trading, Logistics, Procurement, Finance and Information Technology. These incentives were granted in the form of 100% corporate tax exemption for a period of 10 years. The abovementioned incentives were administered by the Malaysian Investment Development Authority (MIDA) and ultimately granted by the Malaysian Ministry of Finance (MOF). These incentives are in the form, of the Operational Headquarters (OHQ), the International Procurement Centre (IPC) and the Regional Distribution Centres (RDC) incentives depending on the activities undertaken by the relevant Malaysian entity. In order to streamline the abovementioned 3 types of incentive, MIDA has, on 6 April 2015, announced a new consolidated incentive called the Principal Hub (PH). This new incentive will be effective from 1 May 2015 onwards and replaces the existing IPC, RDC and OHQ incentives. Qualifying services of the previous incentives are consolidated under PH. * Jobs that require higher and more diverse set of managerial/ technical/ professional skills such as management, analytics, communication, problem-solving and proficiency in information technology ** Qualified companies enjoy a flat corporate tax rate for a period 5 years. Extension of the tax incentive for an additional 5 years is possible. However, they would need to achieve additional 20% and 30% respectively on manpower and annual business spending. Under the PH, MIDA has introduced a new tiered system to distinguish the companies based on the following: The key eligibility criteria are as follows: A local incorporated company with a paid-up capital of more than RM2.5 million. However there is no local equity/ownership condition. Generates a minimum annual sales of minimum RM300 million (for goodsbased companies). Serves and control network companies in at least 3 countries outside Malaysia Carries out at least 3 qualifying services from the 3 clusters namely Strategic Services, Business Services and Shared Services of which one of the services must be from Strategic Services. At least 50% of the employees of high value jobs must be Malaysians by end of year 3. There are several noteworthy differences between the PH incentive and the previous OHQ, IPC and RDC incentives. Firstly, the tiered approach in relation to the corporate tax exemption means that companies no longer enjoy an outright tax holiday for a period of 10 years if they meet qualifying criteria and instead enjoy reduced corporate tax rate depending on the relative contribution to the Malaysian economy in other areas. The rates and duration of the incentive are now based on annual spending and ability to meet the additional manpower and spending requirements mentioned above. The other notable differences are that the company must now perform at least 3 qualifying services, one of which must include any one of the following Strategic Services: i) Regional P&L/ Business Unit ii) Strategic Business Planning and Corporate Development iii) Corporate Finance Advisory Services iv) Brand Management v) IP Management vi) Senior-level Talent Acquisition and Management The need to fulfil the criteria above may require companies to reconsider its business strategy in Malaysia. Companies that are traditionally Procurement Centres enjoying the IPC incentive would now need to expand its service offering and include BDO Asean Investment & Tax News_Rev7_30th JUNE '15.indd 2

3 ASEAN INVESTMENT & TAX 3 FEATURE KEY DEVELOPMENTS IN CORPORATE TAX INCENTIVES FOR GLOBAL/REGIONAL SERVICE CENTRES IN MALAYSIA (continued) at least one of the above Strategic Services in order to enjoy the new PH incentive. In summary, the consolidation of OHQ, IPC and RDC incentives under the PH incentive may ease the administration of the tax incentives by the authorities. However it has also introduced new but more stringent conditions that may be counter-productive in attracting companies to set up these global/regional centres in Malaysia. The introduction of a claw-back of the tax incentive (i.e. the company needs to pay back taxes from year 1 onwards) if the PH company fails to meet the criteria by year 3 of operations may potentially create further complications. It remains to be seen how attractive this new incentive will be to potential investors, particularly with similar incentives available in neighbouring countries such as Singapore and Thailand. However, if the conditions can be met, the incentive will be highly beneficial to companies considering setting global/ regional centres in Malaysia. INDONESIA TAX ALLOWANCE FACILITY A NEW REGULATION The Indonesian government has issued a new regulation (GR 18/2015) on tax allowance facilities available for investments in certain industries and/or regions within Indonesia which is effective from 6 May The tax concessions basically remain as follows, with some changes in the implementation: A reduction of net taxable income at a rate of 30% of the capital investment in tangible assets, including land, used in the main business. This reduction is allowed over six years, at 5% per annum, starting from the commencement of commercial production. Accelerated depreciation and amortization deductions. A reduced withholding tax rate on dividends paid to non-residents at 10% or the applicable tax treaty rate, whichever is lower. Extension of tax losses carried forward beyond the usual five years, but not exceeding 10 years. Key Changes Under the new regulation, the tax allowance facility is available for taxpayers with the following criteria: High value of investment or for export purposes; High utilization of manpower; or High local content. These criteria replace the old requirements of a minimum investment plan of IDR1 trillion with realization of at least 80%, which was a cash flow burden for investors. The detailed restrictions on investment value, number of workers and use of local components under the old regulation (GR 52/2011) were removed, while 14 additional business classification fields BDO Asean Investment & Tax News_Rev7_30th JUNE '15.indd 3

4 4 ASEAN INVESTMENT & TAX (KBLI) were introduced to provide a more flexible and attractive tax facility. The concession to enable tax losses to be carried forward for additional years depends on the satisfaction of certain conditions, namely, the use of certain proportion of local components, employment of a certain number of workers (500 to 1,000 workers) for 5 consecutive years, research and development conducted locally, etc. Limitation The facility is not applicable for taxpayers with tax incentives allowed under the integrated economic development zones (KAPET) under GR 147/2000 and those who are enjoying a tax holiday under GR94/2010. Transitional Rules Tax allowance facilities granted to taxpayers under the old regulations will continue to apply until the end of the grant periods. Recommendations by the Indonesia Investment Coordinating Board (BKPM) to the Ministry of Finance (MoF) prior to the enactment of the new regulations will be processed under the old regulations. However, applications for tax allowance facilities after the enactment of GR 52/2011 but prior to GR 18/2015 may request for the application of the new regulations, provided they satisfy all of the following conditions: No decision has been issued for the investment approval under the old regulations. The industry, business classification fields, product coverage, requirements and/or regions are in line with the new regulations. The commercial production has not yet commenced as at 6 May The recommendation for tax facilities is received by the MoF no later than 1 year after 6 May The applications for the tax allowance facilities will now be processed at the BKPM under their newly introduced one-stop integrated service for permits. This was implemented with the intention of reducing the red tape involved when applying for tax incentives in Indonesia. Under the current practice, such applications may take months, tied up in bureaucracy and administrative procedures. Further application procedures are expected from the BKPM and MoF. VIETNAM NEW CHANGES IN LEGISLATION ON PROPERTY OWNERSHIP 1 July 2015 seems to be a transformative date for Vietnam in Joining the new laws of investment and enterprise, other new laws taking effect on 1 July 2015 are the Law on Real Estate Business (LOREB) and Law on Housing (both Laws were passed at the end of 2014). One of the new changes in legislation involve rules on property ownership. The rules have been expanded to allow foreigners to own properties in Vietnam. The key changes from this perspective are as follows: Overseas Vietnamese now have ownership rights equal to that of local Vietnamese citizens, i.e. freehold tenure. Currently, only registered companies with foreign equity participation can own properties. From 1 July 2015, branches and representative offices of foreign enterprises, foreign investment funds and foreign bank branches can own properties. Foreign individuals permitted to enter Vietnam can now own properties. Conditions under current regulations such as possession of a valid work permit, etc. are now removed. Types of properties that can be owned by foreigners will include landed properties such as villas and townhouses, which, under current regulations, is limited to apartments. There is no limit to the number of properties a foreigner can buy. However, there is a limit on the total number of properties owned by foreign enterprises/ individuals. The limitation is 30% of the total number of apartments in an apartment building or not more than 250 separate houses in one ward. The ownership term of foreign individuals is 50 years and may be extended further. Under the draft decree, foreigners can extend their property ownership by another 50 years. Foreign individuals married to either local Vietnamese or overseas Vietnamese are entitled to freehold tenure. The properties can be sub-leased, traded, inherited or put up as collateral. As for the new LOREB, foreign entities and individuals are permitted to purchase constructed facilities for use as office space or for production purposes. For entities or individuals interested in embarking on real estate business, the minimum legal capital requirement has now been increased to VND20 billion - approximately USD930k (from VND6 billion - USD280k under the current laws). On a positive note, the minimum construction floor requirement for each residential unit has been removed. It is hoped that with the new laws, especially the relaxation of the foreign ownership rules, the real estate market will awaken from the long slumber brought about by oversupply in the past. BDO Asean Investment & Tax News_Rev7_30th JUNE '15.indd 4

5 ASEAN INVESTMENT & TAX 5 MYANMAR NEW TAX LAW OF THE UNION AND COMPETITION LAW 2015 Myanmar has recently enacted the Myanmar Tax Law of the Union 2015 in line with the Government of Myanmar s commitment to continued tax rationalisation. This law came into effect on 1 April Additionally Myanmar also introduced new competition laws, namely, Pyidaungsu Hluttaw Law No.9/2015 (hereinafter referred to as Competition Law). The Competition Law will come into force at a time determined by the President. The above development in Myanmar s tax and competition framework is highlighted below:- TAX LAW OF THE UNION 2015 I. Commercial Tax Myanmar revised the commercial tax rates imposed in respect of selected special goods as well as goods for export. Additionally, Myanmar also revised the list of essential goods and services exempted from the imposition of commercial tax. Lastly Myanmar also increased the threshold for exemption from commercial tax. The changes in the commercial tax regime in Myanmar are further elaborated on as follows:- Special goods The commercial tax rates in respect of 16 special goods have changed from the prevailing commercial tax rates. These special goods include but are not limited to tobacco based products and alcohol. The commercial tax rate on cigarettes has increased from 100% to 120% whereas the rate on other tobacco products, betel chewing preparations, liquor and beer has increased from 50% to 60%. The commercial tax rates applied on rubies, sapphires, emeralds, diamonds and other precious stones will decrease from 30% to 15%, whereas the importation or production of jewellery derived from the same will also decrease from 15% to 5%. Exempted goods and services Under the current law, 84 categories of goods, comprising predominantly essential items such as foodstuffs, medicines, etc. are exempted from commercial tax. Under the new law, the number of categories of goods exempted from commercial tax has been reduced to 79. Examples of categories excluded comprise categories such as computers and telephone handsets, whereas some categories of goods have been included are raw and dried tea leaves, fire trucks and hearses. The Tax Law of the Union 2014 exempted 26 kinds of services from commercial tax. This list has been reduced to 23. Information and technology services, technology and administrative consultant services, container transportation services and slaughter services are no longer exempted whereas license fees to be paid to government organizations are now exempt from commercial tax. Non-exempt services not included in the list are subject to 5% commercial tax. Additionally, the sales proceeds from the construction and selling of buildings are subject to 3% commercial tax. Exported goods The commercial tax rate on the exportation of jade and other precious stones in raw form has been reduced from 30% to 15%. Similar exportation of jade and other precious which comprise finished products has been reduced from 10% to 5%. Additionally, the exportation of electricity will be subject to commercial tax at a rate of 8%. Thresholds for commercial tax exemption The threshold for commercial tax exemption on the production and sale of goods in Myanmar, as well as services provision and trading activities in Myanmar has been increased from MMK15,000,000 to MMK20,000,000. II. Income Tax/ Capital Gains Tax While personal and corporate income tax rates remain unchanged under the Tax of the Union Law 2015 introduced, the new law does introduce some changes to the income tax regime in Myanmar. The Tax Law of the Union sees the introduction of tax relief in respect of parents residing in the common household and who are cared for by the taxpayer, at MMK1,000,000 per parent. Spousal and child relief has also been increased from MMK500,000 to MMK1,000,000 and MMK300,000 to MMK500,000 respectively. The taxation of non-resident foreigners will also be revised under the new law. Nonresident foreigners (individuals residing less than 183 days per year in Myanmar or foreign entities, associations, and organizations including their Myanmar BDO Asean Investment & Tax News_Rev7_30th JUNE '15.indd 5

6 6 ASEAN INVESTMENT & TAX branches) are currently taxed at a rate of 35% on Myanmar sourced income. With the introduction of the Tax of the Union Law 2015, this tax rate has been reduced to 25%. Income of salaried nonresident foreigners is now treated on par with Myanmar citizens and taxed based on a progressive rate between 0% and 25%. The capital gains tax will also lowered from 40% to 10% for industries other than the oil and gas sector. COMPETITION LAW 2015 On February 24, 2015, Myanmar introduced its Competition Law which will come into force at a time determined by the President. The Law lays the framework for the creation of a governing body with investigative and adjudication powers, prohibitions on agreements that restrain competition, abuse of dominance and mergers as well unfair trade practices (UTP), sets out a penalty regime with the potential for private damages conviction of management, right of appeal and a leniency policy. The Law goes on to elaborate on the specific activities which may be construed as conduct restraining competition, abuse of dominance, mergers and UTP. PERSONS/ENTITIES AFFECTED Each prohibition in the Competition Law states the type of entity to which it applies, with acts which restrain competition apply to any person, the monopolization and UTP prohibitions apply to Business Persons and the merger provisions apply to Economic Enterprises. Economic Enterprise is defined as any enterprise engaged in any activity of production, distribution, purchasing, selling, importing, exporting and exchanging as well as any service enterprises and Business person means a person who engages in any economic enterprise or service enterprise. In this expression, organizations engaging in economic activities as well as rendering services shall also be included. REGULATORY AUTHORITY The Competition Law also sets out that the principal regulatory authority under the Competition Law will be the Competition Commission, which is further empowered to establish committees such as an Investigation Committee to investigate conduct that contravenes the Competition Law. The Competition Commission is also empowered to exempt certain industries from the Competition Law, setting the parameters of uncompetitive mergers/ monopolies, instructing businesses to comply with the thresholds set, arranging arranging for exemptions from punishment for infringements to Competition Law, etc. EXCEPTIONS The Competition Law also set out exclusions to the Law where the actions expressly have the effect of increasing efficiency, developing technology or technological standards, increase the quality of products, relating to issues of operations, distribution or payment that do not relate to price, promoting competitiveness of SMEs or promoting the competitiveness of Myanmar businesses internationally. Additionally, the Competition Law also permits an otherwise prohibited merger where the resulting enterprise remains a SME, one of the merging parties was, or was likely to become, bankrupt or the merger promotes exports or development of technology, systems or innovation. PENALTIES The Competition Law sets out penalties for contravention of various aspects of the Competition Law up to imprisonment of up to 3 years and a fine up to MMK15,000,000 or both for particular offences. OTHERS The Competition Law also recognises the possibility of civil action against any person convicted under the Competition Law. The Law also allows the Competition Commission to recommend reduced or total relief from penalties to offender who confesses to breaches of the Law in court or law offices under a leniency policy. Lastly, the Law provides for the right of offenders to appeal against the findings of the Competition Commission. NEXT STEPS The Competition Law contains comprehensive prohibition in respect of certain anti-competitive acts, abuses of dominance, mergers and UTP businesses need to be aware of. As such, businesses should take proactive steps to audit their existing structures and prevailing conduct to ensure they do not fall foul of the Competition Law as drafted. Additionally, any new businesses must take the prohibitions in the Competition Law into account whenstructuring said business in Myanmar. Lastly, businesses need to keep abreast of developments issued by the Competition Commission in anticipation of further clarification of the permitted thresholds to definitions in the legislation. BDO Asean Investment & Tax News_Rev7_30th JUNE '15.indd 6

7 ASEAN INVESTMENT & TAX 7 THAILAND PRIME MINISTER ORDERS DELAY OF THE NEW HOUSE AND LAND TAX The Prime Minister has cited the slowdown of the Thai economy and its potential negative impact on low income earners in his decision to defer the introduction of a new house and land tax. The new tax legislation that was drafted would instead be treated as a long term plan for tax reform and its implementation would be further studied. House and land tax is currently imposed at the rate of 12.5% on the rental value of commercial properties. The new tax proposed by the Finance Ministry would be calculated on a property's official appraised value, with the rate of tax imposed depending on the use of the property. NATIONAL LEGISLATIVE ASSEMBLY MAY AMEND THE INHERITANCE AND GIFT TAX In November 2014, the Thai Cabinet approved a draft bill submitted by the Finance Ministry which imposes tax on assets passed to family members on death. The bill proposed that a 10% tax will apply to assets inherited greater than Baht 50 million. At the same time, the Cabinet also approved proposed amendments to the Revenue Code to impose a 5 percent tax on gifts to children or grandchildren of greater than Baht 10 million in order to prevent evasion of inheritance tax. The bills were passed to the National Legislative Assembly for consideration and concerned that the new taxes could have an adverse effect on the low-income earners, the Assembly plans to amend the proposed laws to increase the inheritance tax threshold from Baht 50 million to Baht 100 million and the gift tax threshold from Baht 10 million to Baht 20 million. WITHHOLDING TAX REDUCTION BEING STUDIED In Thailand, a 3% withholding tax has applied for a long time to income derived by corporate taxpayers from the provision of services and similar types of income. The withholding tax is allowed as a credit against income tax payable on a company's net profit and hence is meant to be a way of collecting tax as income is derived. In recent years, Thailand has reduced corporate tax rates to improve its competitiveness with the corporate tax rate now currently now standing at 20%. A withholding tax rate of 3% is not compatible with the reduced corporate tax rate, leading to more companies paying withholding tax greater than their actual corporate tax liability. The Fiscal Policy Office is conducting a study on reducing the rate and plans to propose to the Finance Ministry to reduce the withholding tax rate to 2%. SINGAPORE EVOLUTION OF SINGAPORE FOREIGN INCOME TAX EXEMPTION The Singapore tax regime on foreign income started to evolve with the introduction of the Foreign Source Income Exemption (FSIE) regime in The FSIE regime was introduced to encourage remittance of foreign income, however, it is only applicable to foreignsourced dividends, foreign branch profits and foreign-sourced service income and subject to meeting qualifying conditions subject to tax; foreign headline tax rate of at least 15%; and beneficial tax exemption. In 2006, the scheme was further enhanced to exempt specified foreign income arising from substantive business activities carried out overseas. Certain foreign-sourced income received in Singapore by resident companies under six specified scenarios and certain foreign income received by trustees of Real Estate Investment Trusts listed on SGX is also exempt from tax. Where the specified foreign income does not fall squarely into the specified scenarios, case-by-case approval from the Ministry of Finance may be sought. Despite the enhancements, there remain practical obstacles. For example, investors who invest in overseas shares through their brokers in Singapore and receive foreign dividends may only have a subsidiary dividend certificate issued by their brokers. Such documentation generally does not contain sufficient information to determine whether the exemption conditions are met. The organizational structure of listed companies is generally complicated and the taxpayers will encounter difficulties tracing, analysing and confirming whether the conditions for exemption are met. In the case of foreign-service income, to qualify for an exemption, the service has to be provided through a fixed place of operation in the foreign country i.e. Permanent Establishment (PE). If the service is not provided through a PE, the service income may be considered Singapore-sourced. If the foreign country has signed a tax treaty with Singapore, generally service income would not be subject to foreign tax if no PE exists. However due to practical reasons, the foreign payer may typically withhold tax BDO Asean Investment & Tax News_Rev7_30th JUNE '15.indd 7

8 8 ASEAN INVESTMENT & TAX on service payment according to domestics rules, unless the Singapore recipient can prove no PE is created. This imposes a burden of proof on the taxpayer. To expedite the matter, Singapore companies may choose to pay the foreign tax. In the absence of a PE tax filing documents in the foreign country, Singapore companies may suffer double taxation as neither tax exemption nor foreign tax credit claims would be available. The conditions had inevitably presented difficulties for the exemption claims and impede remittance of foreign income. As the marketplace becomes increasingly global, more and more enterprises go beyond borders. More and more foreign income generated offshore may not be remitted to save tax. After 12 years of FSIE regime, it is probably time to re-look at the rules and consider lifting the conditions. Compared to Hong Kong and Malaysia which exempt tax on all foreign-sourced income, Singapore s system appears complicated. As Singapore continues to attract foreign investments through various incentives, a more favourable FSIE regime may further enchance its attractiveness. CONTACTS For more information, please contact the following BDO offices in ASEAN. BRUNEI Tel: Fax: info@bdo-bn.com CAMBODIA Tel: Fax: info@bdo.com.kh INDONESIA Tel: Fax: bdoidn@bdo.co.id MALAYSIA Tel: Fax: bdo@bdo.my MYANMAR Tel: Fax: myanmar@bdo.my PHILIPPINES Tel: Fax: cpas@bdoalbaromeo.ph SINGAPORE Tel: Fax: info@bdo.com.sg THAILAND Tel: Fax: bdo@bdo.co.th VIETNAM Tel: Fax: bdo@bdo.vn LAO PDR Please contact BDO Cambodia ASEAN Investment & Tax News is published by: BDO Tax Services Sdn Bhd Level 8, Menara CenTARa, 360 Jalan Tuanku Abdul Rahman, Kuala Lumpur Tel: Fax: bdo@bdo.my Printed by: Nets Creative Station Sdn Bhd 56, Jalan PBS 14/4, Taman Perindustrian Bukit Serdang Seri Kembangan, Selangor Tel: Fax: netscreative@gmail.com... This publication has been carefully prepared, but it has been written in general terms and should be seen as broad guidance only. The publication cannot be relied upon to cover specific situations and you should not act, or refrain from acting, upon the information contained therein without obtaining specific professional advice. Please contact BDO Tax Services to discuss these matters in the context of your particular circumstances. BDO Tax Services, its partners, employees and agents do not accept or assume any liability or duty of care for any loss arising from any action taken or not taken by anyone in reliance on the information in this publication or for any decision based on it. BDO International is a world wide network of public accounting firms, called BDO Member Firms. Each BDO Member Firm is an independent legal entity in its own country. The network is coordinated by BDO Global Coordination B.V., incorporated in the Netherlands with its statutory seat in Eindhoven (trade register registration number ) and with an office at Brussels Airport, The Corporate Village, Elsinore Building, Leonardo Da Vincilaan 9 5/F, 1935 Zaventem, Belgium, where the international Executive Office is located. BDO (AF 0206) Chartered Accountants, a Malaysian Partnership, is a member of BDO International Limited, a UK company limited by guarantee, and forms part of the international BDO network of independent member firms. BDO is the brand name for the BDO network and for each of the BDO Member Firms. BDO Asean Investment & Tax News_Rev7_30th JUNE '15.indd 8