Amy's International tax

 Malaysia is introducing the Stamp Duty Self-Assessment System (SDSAS) progressively, based on the nature of the instruments or agreements involved. Concurrently, the tax authorities have also launched the Stamp Duty Audit Framework (SDAF), which came into effect on January 1, 2025. This framework aims to ensure that stamp duty audits are conducted with fairness, transparency, and impartiality, clearly defining the rights and obligations of those being audited and the auditing officers. Considering these developments, taxpayers should anticipate a rise in stamp duty audits in the near future. This underscores the importance of having a robust stamp duty risk management framework in place. It is now essential for taxpayers to possess a thorough understanding of stamp duty regulations and to establish clear protocols for ensuring all necessary documents are stamped promptly. ----  Future obligations under the upcoming Stamp Duty Self-Assessment System (SDSAS) and the implicati...

The judgement for the pricing agreement was recently released.  The case was determined in favor of the taxpayer (see page 213), however the decision was not based on law, but rather on a balance of probabilities and from testimony from witnesses, due to the lack of documentation from the period in question.  As such, if the company wishes to claim the expenses for the prior years, we have also summarized the sums treated as non-deductible amount G. DISPOSITION 83. For reasons as have been enunciated hereinabove, it is therefore our decision that: - a. the assessment made by the Respondent on the Appellant for the year of income 2005 with respect to Corporation Tax and in which the Respondent assessed the Appellant to additional sales revenue of $439, 183,501 and to have also reduced the Appellant’s losses carried forward from $73,754,282 to nil to be unjustified as a matter of fact and law; and b. the total adjustments to sales made by the Respondent on the Appellant for the ...

 Q- What is the difference between service provider and manufacturer? If the entity perform engine overhaul activity, should we use service benchmark or manufacturer benchmark for TP purposes? Difference Between Service Provider and Manufacturer The core difference lies in the nature of their primary output and the transformation process: Manufacturer: Primary Output: Creates tangible goods or physical products.   Process: Transforms raw materials or components into finished products through processes like fabrication, assembly, chemical processing, etc.   Value: The value is primarily embodied in the physical product itself. Examples: Car maker, electronics producer, furniture builder, chemical plant. Characteristics: Often involves significant investment in plant/machinery, manages inventories of raw materials, work-in-progress, and finished goods. Service Provider: Primary Output: Provides intangible actions, expertise, or access to resources. ...

the difference between Supply Chain Management (SCM) and Procurement. Think of it this way: Procurement is one important part of the larger Supply Chain. Here's a more detailed comparison: Procurement: Focus: Primarily concerned with the acquisition of goods, services, or works needed by an organization. It's about buying things. Scope: Narrower. It involves the processes directly related to purchasing inputs. Key Activities: Identifying needs for goods/services.   Sourcing and selecting suppliers. Negotiating contracts and pricing.   Placing purchase orders. Managing supplier relationships (often focused on specific transactions or contracts).   Ensuring compliance with purchasing policies.   Receiving goods/services (sometimes overlaps with logistics).   Goal: To acquire the necessary inputs at the best possible price, quality, and terms, while mitigating purchasing-related risks. 1 Often focuses on cost savings and supplier performa...

 General Rule:  The term "capitalized income" is a bit ambiguous in tax contexts. The tax treatment depends heavily on what exactly is being capitalized. Here are a few scenarios: Capitalized Interest Expense: If you are referring to interest expense that is capitalized (i.e., added to the cost basis of an asset being constructed or produced, instead of being expensed immediately), this is not income at all. It's an accounting and tax treatment for an expense . Capital Gains: If "capitalized income" refers to the profit realized from the sale of a capital asset (like stocks, real estate), this is treated as capital gains income , which is typically taxed differently than interest income. Accrued Interest Added to Principal (Capitalized Interest Income): This seems the most likely interpretation matching your phrasing. If interest income that is earned (accrued) on an investment or loan is not paid out in cash but is instead added to the outstanding prin...

  Capitalized interest specifically in the context of an intercompany loan. 1. Intercompany Loan Basics: An intercompany loan is simply a loan made between two related companies within the same corporate group (e.g., a parent company lending to a subsidiary, or one subsidiary lending to another). Like any loan, it typically carries an interest rate. The borrowing company incurs interest expense, and the lending company earns interest income. Transfer pricing rules generally require this interest rate to be set at "arm's length," meaning similar to what unrelated parties would agree to. 2. Capitalized Interest (General Accounting Principle): Normally, interest expense incurred by a company is recorded on its income statement in the period it's incurred, reducing net income.   However, accounting standards (like US GAAP ASC 835-20 or IFRS IAS 23) require or permit companies to capitalize interest costs under specific circumstances. Capitalization means adding the...