Earning Stripping Rules & Other Restrictions on Tax
Total Page:16
File Type:pdf, Size:1020Kb
CPE POINTS AWARDED 8 CPE hours will be awarded and will qualify as CPE Points for the purpose of application or renewal of tax agent licence under Subsection 153(3), Income Tax Act 1967. EARNING STRIPPING RULES & OTHER RESTRICTIONS ON TAX DEDUCTIBILITY OF INTEREST 22 August 2019 (Thursday) Connexion Conference & Event Centre @ The Vertical, Bangsar South, Kuala Lumpur Following BEPS Action 2, Malaysia introduced a new restriction on deductibility of interest expense, commonly known as Earning Stripping Rules (ESR). This applies together with other restrictions in the Income Tax Act. The ESR applies to companies with annual interest cost exceeding RM500,000. For other businesses, other restrictions continue to apply. Gain insights into the ESR and other interest restrictions in order to navigate this era where interest expenses are subject to multiple scrutiny. OBJECTIVES PROGRAMME OUTLINE This programme seeks to help you to: • Introduction to Earning Stripping Rules (ESR) • Understand the application of ESR > Purpose > Scope • Understand the rules related to deductibility of interest expenses • The ESR Mechanism > What companies should do to comply • Subsection 33(2) of the Income Tax Act WHO SHOULD ATTEND > Interest restriction rules • Finance Directors • Withholding Tax • Finance Managers > Restriction on deductibility • Tax Agents • Interest Payment to Labuan Companies • Transfer Pricing Consideration METHODOLOGY • No Tax Deduction Until Interest is Due Lectures accompanied with practical examples. > To bear in mind when drafting intercompany loan agreements • Interest-free Loans • Guarantee Fee Earning Stripping Rules & Other Restrictions With immediate effect, enrolment for all CPE programmes will be on Tax Deductibility of Interest STRICTLY VIA ONLINE REGISTRATION ONLY REGISTRATION PROCESS FACILITATORS • To view more events and download full brochure, AMIR ZAINUDDIN BIN ABDUL HAMID please visit: Amir is currently the Principal Assistant Director of the Inland Revenue Board pd.mia.org.my of Malaysia, joining IRBM in 2002. He is in charge of transfer pricing policies • Search and select the event under the Department of International Taxation. He is also involved in OECD Working Party 6 • Click ‘Register’ to experience the new system by on Taxation of Multinational Enterprises, and is one of continuing with the respective steps below: the resource persons for transfer pricing course at the Malaysian Tax Academy and Taxation of International Transaction. He holds a Bachelor of Accountancy degree from University Putra Malaysia and a Master in EXISTING USER Business Administration from University Kebangsaan Malaysia. 1 2 3 THENESH KANNAA PROCEED Thenesh Kannaa is a partner at TraTax, a ENTER SELECT TO REGISTER login credentials an event firm of independent tax advisers ranked FOR THE EVENT within top 10 in Malaysia for transactional tax. Thenesh is a fellow member of ACCA (UK) and CTIM, a member of MIA and IFA (Netherlands). He is a licensed tax agent (Malaysia) and holds a diploma in International Taxation from NEW USER Leiden University, Netherlands. He has authored three books on Malaysian taxation 1 2 SELECT 3 published by Wolters Kluwer (CCH), and a wide range appropriate VALIDATE of articles on contemporary tax matters for MIA’s CLICK ON user profile; the email address Accountants Today, CTIM’s Tax Guardian, ACCA’s AB “Don’t have an account?” verification link sent to ENTER magazine, and the Taxation Institute of Hong Kong’s the registered email Asia-Pacific Journal of Taxation. He is also the author details and submit of the Malaysian chapter of the Holding Companies Database published by IBFD, Amsterdam. He has also been interviewed on contemporary tax matters by TV2, Bernama TV, the Traxx.fm (RTM4), Astro, New 6 5 4 Straits Times, the Sun and Malaysia SME. PROCEED TO REGISTER SELECT ENTER Thenesh is a member of various committees that an event login credentials provide input to the Government on tax matters, FOR THE EVENT including CTIM's Technical Committee on Direct Taxation I and Transfer Pricing. In IFA’s Regional Tax Conference 2017 held in New Delhi, Thenesh presented on a BEPS topic in a panel session with a senior representative of OECD and fellow international For any assistance, please call (8.45am-5.30pm, Monday-Friday) tax practitioners. MIA Help Desk @ 603-2722 9000 PROGRAMME FEES TERMS & CONDITIONS Member / Member Firm | RM 650 PROGRAMME FEE Non-member | RM 850 • Fee is payable to MALAYSIAN INSTITUTE OF ACCOUNTANTS • Depending on the event, the fee includes course materials and/or lunch and/or tea breaks. * Preferred Payment: Pay with MIA-CIMB Affinity • Individual Registration: Full payment shall be made at the point of online registration. Credit Card. • Corporate Registration: Full payment shall be made within thirty (30) days from the date of the Proforma Invoice or on the day of the event, whichever earlier. • Admittance may be denied upon failure to make full payment as per the above requirement. PROGRAMME DETAILS & REGISTRATION CANCELLATION Should the participant decide to cancel his/her enrolment, a cancellation policy shall be applied as follows: 22 August 2019 (Thursday) a. Written cancellation received less than seven (7) days from the date of the event: Connexion Conference & Event Centre - A refund (less administrative charge of 20%) will be made. - Unpaid registrations will also be liable for 20% administrative charges. @ The Vertical, Bangsar South, Kuala Lumpur b. Written cancellation/no show on the day of the programme: - No refund will be entertained. Contact : Azie - Unpaid registrations will also be liable for full payment of registration fee. Tel : 03 2722 9265 Substitutes for cancellation will be treated as a new registration and full payment shall be made as per the above requirement. Fax : 03 2722 9009 PARTICIPANT’S CLASSIFICATION AND INFORMATION Email : [email protected] Category: Corporate / Individual Address : Malaysian Institute of Accountants • Please select the participant classification carefully as it determines the fee payable. No alteration will be allowed upon registration. Dewan Akauntan • The information on Corporate/Individual provided shall be deemed true and correct. No alteration will be allowed upon registration. Unit 33-01, Level 33 VERIFICATION OF ATTENDANCE Tower A, The Vertical • All participants are required to present photo identification (NRIC, driving licence or company’s ID card) at the point of registration prior to Avenue 3, Bangsar South City signing the registration list when attending MIA CPE programme. Admittance may be denied upon failure to present photo identification. No. 8, Jalan Kerinchi CERTIFICATE OF ATTENDANCE AND CPE HOURS 59200 Kuala Lumpur • Upon full attendance of the programme, participants will be issued an “e-certificate”. For this purpose, it is COMPULSORY to fill in the email address clearly. • For MIA members, the CPE hours will be credited into the Membership System within 2 weeks of the event. • Participants will only be entitled to the CPE hours upon attending the entire duration of the programme. CPE hours will not be accorded for partial attendance. DATA PROTECTION Personal Data is gathered in accordance with the Personal Data Protection Act 2010 (Act 709). DISCLAIMER GROUP DISCOUNT Malaysian Institute of Accountants (MIA) reserves the right to change the speaker(s), date(s) and to cancel the programme should circumstances beyond its control arise. MIA shall not be responsible for any costs, damages or losses incurred by the participant due 5% DISCOUNT ON TOTAL FEE to the changes and/or cancellation. MIA also reserves the right to make alternative arrangements without prior notice should it be FOR 3 PAX AND ABOVE FROM THE necessary to do so. Upon registering, you are deemed to have read and accepted the terms and conditions herein. SAME ORGANISATION.