Cross Border Transactions and Withholding Tax

INTRODUCTION

• Overview of taxation issues for outbound and inbound investments
• Withholding tax and permanent establishment considerations
• Royalties, interest, technical fees and withholding tax implications
• Special Classes of Income under Section 4A of the Income Tax Act, 1967
• Section 109B vs Section 107A of Income Tax Act, 1967 – how it is applied in practice
• Tax treatment of foreign source income
• Rules to consider in determining if income is Malaysian derived income
• Determination of Permanent Establishments and the income tax implications
• Tax treatment of cross border sales / purchase of assets
• Double Taxation agreements
• Avoidance of double taxation
• Tax havens and overseas holding company structures
• Anti-avoidance issues
• Case studies

COURSE OUTLINE

PROFILE(s)

Harvindar Singh is a Fellow of Chartered Association of Certified Accountants and is a member of the Malaysian Institute of Accountants (MIA) as well as the Chartered Tax Institute of Malaysia (CTIM). Harvindar was attached to the tax divisions of PWC and E&Y as a tax consultant and is currently the Managing Partner of Harvey & Associates, a boutique firm that specialises in taxation consulting services as well as the Tax Partner in SCS Global Consulting (M) Sdn Bhd. Harvindar has more than 29 years of extensive experience in taxation advisory, transfer pricing documentation preparation, tax planning as well as tax audits and investigations and he serves as a Tax Specialist to numerous corporate entities such as SK International (M) Sdn Bhd and other MNEs and organisations. He is currently serving as the Chairman of the Editorial Board of the Budget Commentary and Tax Information Booklet which is produced jointly by MIA, CTIM and MICPA. Mr Harvindar is a Council Member of CTIM.