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 […]
LHDN: Media Statement – Special Program For Revenue Saved Abroad
Special Program For Revenue Saved Abroad 9
No More Exemption on Foreign Sourced Income Remitted to Malaysia
1. No more Exemption on Foreign Sourced Income remitted to Malaysia! 2. This is undoubtedly a contentious subject, as many taxpayers were taken aback by the move in Budget 2022 to tax foreign-sourced income received by Malaysian individuals and corporate residents. 3. Any taxes paid outside of Malaysia on the foreign income remitted can be […]
Multilateral Convention to Implement Tax Treaty Related Measures to Prevent BEPS
1. On 24 November 2016 the Organisation for Economic Co-operation and Development [OECD] published its 15th action plan for the implementation of Base Erosion and Profit Shifting [BEPS] – Multilateral Instrument ]. 2. 18 February 2021, Malaysia deposited its instrument of ratification of the Multilateral Convention on the Implementation of Measures relating to Tax Treaties […]
United Nations : Releases New 2021 Practical Manual on Transfer Pricing
1. this third edition of the Manual: 🌼🌼🌼🌼🌼🌼🌼🌼🌼🌼 1. 此手册的第三版: 👉 改进了可用性和实际相关性， 👉 在现有文本内，更新和改进了包括国家实践（D 部分），并增加了新内容，特别是关于金融交易、利润分配、集中采购功能 [centralized procurement functions] 和可比性问题。 👉 也针对手册中的信息和使用的示例，改进研发能力 10
