The Inland Revenue Board of Malaysia (IBRM) has recently published two different sample notification letters for entities subject to the country-by-country (CbC) reporting notification requirement.
Two separate sample notifications letters have been issued, one for reporting entities (ultimate holding companies or surrogate holding companies that are tax resident in Malaysia) and the other for non-reporting entities.
The Malaysian Income Tax (Country-by-Country Reporting) Rules 2016 (The Rules) P.U.(A) 357/2016 has been gazetted on 23 December 2016. The Rules applies to Multinational headquartered in Malaysia, having total group revenue of more than RM3 billion in the year 2016 in which they are required to furnish their aggregate tax jurisdiction-wide information relating to the global allocation of the income, taxes paid and certain indicators of the location of economic activity among tax jurisdictions in which the multinational company group operates. The information to be furnished is pertaining to the financial information of 2017 onwards.
The Ultimate Holding entity of the multinational company group headquartered here is responsible to prepare and file the CbCR to IRBM within one year from the end of their financial year. Malaysian taxpayer who is part of the multinational company group that is subject to prepare CbCR in another country, will need to notify the revenue board of their reporting entity and its residency, before the end of their financial year.
