CCS

9: The principle of Territorial cum Residence Jurisdiction

The principle of Territorial cum Residence Jurisdiction – PDF 1. The principle of Territorial cum Residence Jurisdiction refers to the taxation jurisdiction of a country that simultaneously exercises both Territorial [source jurisdiction] Jurisdiction and Residence Jurisdiction. 2. It can be further divided into: 👉 Territorial-Citizen Jurisdiction, 👉 Territorial-Residence Jurisdiction; and 👉 Territorial-Residence-Citizen Jurisdiction. 3. Foreign-sourced […]

11: Double Taxation vs Double Non-taxation

Double Taxation vs Double Nontaxation – PDF 1. If the conflicting claims for tax revenue based on residency and source are not addressed effectively, it would result in Double Taxation, which will stymie international companies and investment. 2. While multinational businesses may suffer double taxes, they also have possibilities for international tax avoidance (sometimes referred […]

12: The International Double Taxation – Legal

The International Double Taxation – Legal – PDF 1. Two basic concepts that are also essential reasons/causes of international juridical double taxation are at the heart of international taxation concerns. 👉 The terms “source” and “residence” are used to describe these two concepts. 👉 Both concepts are derived from laws in domestic tax legislation that […]

13: Methods used by Resident Countries to Cope with Double Taxation

1. Budget 2022 was tabled in Parliament on 29 October 2021, one of the amendments to the Income Tax Act 1967 is: 👉 Foreign-sourced income received in Malaysia will be taxed from January 1, 2022. 2. Then, everyone noticed a lot of relevant news or posts on social media 3. I’m also keeping track of […]

14: The International Double Taxation – Economic

The International Double Taxation – Economic – PDF 1. Yesterday, George Tan enquired, “How will future dividends received from Singapore be taxed?” 2. To be honest, this is an interesting question that cannot be answered succinctly in a few lines. 3. The taxation of dividends has its origins in the classical tax system, which in […]

10: Special Income Remittance Programme to Malaysian Residents

1. In a statement issued on November 16, 2021, IRB said this Special Income Remittance Programme to Malaysian Residents (“PKPP” was in line with Finance Minister Tengku Datuk Seri Zafrul Tengku Abdul Aziz’s announcement in the Budget 2022 that the tax exemption for foreign sources of income will be removed. 2. According to the programme, […]

6: Jurisdiction to Tax – Introduction

Jurisdiction to Tax – Introduction – PDF 1. Under a country’s tax law, income may be taxed if there is a nexus between that country and the activity that generated the income. According to international practice, the assertion of jurisdiction based on this nexus is called “Source Jurisdiction [Territorial Concept].“ 2. All countries that impose […]

7: Jurisdiction to Tax – Source Jurisdiction

Jurisdiction to Tax – Source Jurisdiction [税收管辖区 – 来源地管辖权] – PDF 1. Source jurisdiction for tax purposes means that a country (let’s assume it’s your country) taxes non-resident individuals and corporations on income generated within that country (i.e., from your country). 2. In principle, this tax regime is aimed at income derived by non-residents from […]

8: Jurisdiction to Tax – Residence Jurisdiction

Jurisdiction to Tax – Residence Jurisdiction [税收管辖区 – 居民管辖权] – PDF 1. Resident jurisdiction involves taxing the foreign-source income (of course, also including your country itself) of individuals and corporations resident in your country, which means taxing the taxpayer’s worldwide income. 2. This includes the income derived by residents from the sale (or provision for […]