The ruling confirms the 70% loss surrender limit and introduces a three-year cap for newly established companies, alongside new definitions, examples, and clarifications.
The Inland Revenue Board of Malaysia has issued Public Ruling No. 2/2025, outlining the tax treatment of group relief for companies incorporated and tax resident in Malaysia.
The Ruling reiterates that companies may surrender up to 70% of adjusted business losses to related companies, and introduces new guidance effective YA 2019 limiting newly commenced companies to surrendering current-year losses for only three consecutive YAs.
The ruling also adds definitions, updated numbering, examples, and other clarifications.