Tag: Foreign-Sourced Income

16: Defining Residence

Defining Residence – PDF 1. With effect from 1 January 2022, Malaysian tax residents will no longer be exempt from taxation on income received in Malaysia that originates from abroad (Foreign Source Income), which raises a number of issues, including pensions from abroad (e.g. Singapore). 2. You’ll realise that we’re talking about Malaysian tax residents […]

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, […]

2: International Organizations involved In International Tax – OECD

1. Despite the fact that sovereign nation-states are largely responsible for creating the rules of the international tax system through domestic law and tax treaties, other international organisations play a significant role in international tax. 2. The OECD, the International Monetary Fund (IMF), the United Nations (UN), and the World Bank Group (WGB) are the […]

3: International Organizations involved In International Tax – Group of Twenty

1. The Group of Twenty (G20) and the OECD initiated a cooperative endeavour in 2012 to combat Base Erosion and Profit Shifting (“BEPS”). 2. The OECD’s Action Plan on BEPS was released in 2013, outlining a robust agenda with fifteen specific action items; the final reports were released in October 2015. (available at www.oecd.org). 🌻🌻🌻🌻🌻🌻🌻🌻🌻🌻🌻 […]

4: International Organizations involved In International Tax – G20

1. The OECD, the International Monetary Fund (IMF), the United Nations (UN), and the World Bank Group (WGB) are the four primary international organisations involved in international taxation. 2. The G20/OECD Inclusive Framework, the International Monetary Fund [IMF], and the World Bank Group [WBG] will all be discussed today. 🌻🌻🌻🌻🌻🌻🌻🌻🌻🌻🌻 1. 经合组织 [OECD]、国际货币基金组织 [IMF]、联合国 [UN] […]