Here are some international tax issues we should watch out for in 2023.
There has been a phenomenal eCommerce expansion, and the modus operandi for doing business has seen a paradigm shift. Today, working from home is the norm, and the latest technology in virtual meetings and communications is key to executing deals.
However, remote working may create several unintended tax consequences. For example, a foreign IT consulting company allows its engineers to work from anywhere in the world, and a non-Malaysian citizen personnel has chosen to work from Malaysia. The foreign operating models of Malaysia-headquartered MNCs as well as Malaysian operations of foreign-based MNCs should be reviewed.
Where a taxable presence exists, the profit attribution exercise could be complex and is often subject to debate.GMT is applicable to multi-national companies operating in at least two jurisdictions, with an annual consolidated group revenue of at least �750mil in at least two of the four immediately preceding fiscal years of the tested fiscal year.
Early understanding of the impact of GMT and preparation will be key to an effective and efficient implementation. FSI of a Malaysian tax resident will be subject to Malaysian income tax when it is received in Malaysia , where the FSI is taxed at a concessionary rate of 3% on a gross basis.
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