Offshore Tax with HTJ.tax

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- Updated daily, we help 6, 7 and 8 figure International Entrepreneurs, Expats, Digital Nomads and Investors legally minimize their global tax burden and protect their wealth. - Join Amazon best selling author, Derren Joseph, in exploring the offshore financial world. Visit www.htj.tax

  1. 7h ago

    How Did Malaysia’s Foreign Income Tax Rules Change in 2022?

    How Did Malaysia’s Foreign Income Tax Rules Change in 2022?Before 1 January 2022, Malaysia generally provided a broad exemption for foreign-sourced income received in Malaysia. From 1 January 2022, that blanket exemption was removed. As a result, foreign-sourced income received in Malaysia by a Malaysian tax resident generally became subject to Malaysian income tax, subject to specific exemptions and transitional measures introduced subsequently. Key takeaway: The 2022 reform marked a significant shift from Malaysia’s previous broad exemption approach toward a taxation-on-receipt/remittance framework, although subsequent exemptions mean the current treatment depends on the type of income and taxpayer.

  2. 1d ago

    Is London Rental Income Taxable in Hong Kong?

    Is London Rental Income Taxable in Hong Kong?Generally, no. Rental income from property located in London is foreign-sourced income and is generally not subject to Hong Kong Profits Tax or Salaries Tax, provided the rental activity does not form part of a trade, profession, or business carried on in Hong Kong. Key takeaway: Simply being a Hong Kong resident or receiving London rental income in Hong Kong does not, by itself, make the rental income taxable in Hong Kong. The nature and source of the rental activity must still be considered.

  3. 2d ago

    Which Entities Are Excluded from Hong Kong’s FSIE Regime?

    Which Entities Are Excluded from Hong Kong’s FSIE Regime?Yes. Certain entities are excluded from the Hong Kong FSIE regime for specified types of foreign-sourced income. The exclusion can apply to foreign-sourced interest, dividends, and non-IP disposal gains accruing to: Regulated financial entities, such as authorized insurers, banks, or licensed securities dealers; orTraders, where the relevant income is derived from or incidental to their regulated or trading business. Key takeaway: The FSIE regime does not apply uniformly to every MNE entity. Where a regulated financial entity or qualifying trader falls within the relevant exclusion, specified foreign-sourced income may remain outside the FSIE regime.

  4. 3d ago

    Are Labuan Companies Subject to Malaysia’s Remittance Rules?

    Are Labuan Companies Subject to Malaysia’s Remittance Rules?Generally, no. Labuan entities are subject to the Labuan Business Activity Tax Act 1990 (LBATA) rather than Malaysia’s ordinary income tax regime, subject to the nature of their activities and applicable conditions. Non-trading activities: A Labuan entity may generally elect to pay either RM20,000 or 3% of audited net profits, subject to the applicable rules.Trading activities: A qualifying Labuan entity that satisfies the relevant substance requirements may benefit from the 3% tax rate rather than a 0% rate. Key takeaway: Labuan companies should not simply be treated as ordinary Malaysian companies for remittance-tax purposes. Their tax treatment depends on their Labuan status, business activity, substance, and the specific income involved.

  5. 4d ago

    What Is the Nexus Requirement for IP Income in Hong Kong?

    What Is the Nexus Requirement for IP Income in Hong Kong?Under Hong Kong’s FSIE regime, the nexus requirement limits the amount of foreign-sourced IP income that can qualify for exemption based on the proportion of qualifying R&D expenditure incurred in developing the relevant IP asset. Qualifying expenditure generally includes R&D activities carried out by: The Hong Kong entity itself;An associated person; orA non-associated person. The greater the proportion of qualifying R&D expenditure relative to the total expenditure incurred to develop the IP asset, the greater the proportion of IP income that may qualify for exemption. Key takeaway: The nexus approach links the tax benefit directly to the substantive R&D activity supporting the IP, rather than simply where the IP is legally owned.

  6. 5d ago

    How Does Malaysia Source Employment Income?

    How Does Malaysia Source Employment Income?Under Section 13 of Malaysia’s Income Tax Act 1967, employment income is generally sourced based on where the employment is physically exercised. Therefore, employment income is generally treated as Malaysia-sourced when the employee performs their duties in Malaysia, regardless of: Where the employment contract was signed;Where the employer is located; orWhere the salary is paid. Key takeaway: For Malaysian employment income, the place where the duties are physically performed is the key sourcing factor—not the location of the employer, contract, or bank account.

  7. 6d ago

    What Does Participation Exemption Mean Under Hong Kong FSIE?

    What Does Participation Exemption Mean Under Hong Kong FSIE?Under Hong Kong’s FSIE regime, the participation exemption can provide an alternative exemption route to the economic substance requirement for certain foreign-sourced dividends and equity interest disposal gains. To qualify, broadly, the MNE entity must: Be a Hong Kong tax resident or have a permanent establishment (PE) in Hong Kong;Hold at least 5% of the equity interest in the investee entity;Have held that interest for a continuous period of at least 12 months before the relevant income accrues; andSatisfy the applicable subject-to-tax requirement in relation to the foreign jurisdiction. The foreign tax condition should be applied carefully because the FSIE rules contain specific statutory tests and exceptions rather than a simple universal 15% rule. Key takeaway: Participation exemption is essentially an ownership-based route: instead of relying on Hong Kong economic substance, a qualifying MNE entity may rely on its substantial, long-term participation in the investee, provided the oth

  8. Aug 27

    When Are Directors’ Fees Taxable in Singapore?

    When Are Directors’ Fees Taxable in Singapore?The Singapore tax treatment of directors’ fees depends primarily on the residence of the company paying the fees, rather than simply where the director happens to attend meetings. 🇸🇬 1️⃣ Foreign Company With No Singapore PresenceGenerally, directors’ fees from a company that has no presence in Singapore are not taxable in Singapore, even if the director occasionally attends board meetings in Singapore. The general principle is that directors’ fees are sourced in the country where the company is resident. Therefore, physically holding a board meeting in Singapore does not, by itself, necessarily make the director's fees Singapore-sourced. 💼 2️⃣ Other Payments for Duties in SingaporeThe position can be different for other payments relating to duties actually performed in Singapore. For example, remuneration for services carried out in Singapore may be subject to Singapore income tax even where the payer is an overseas company. The distinction between directors' fees and other employment or service remuneration is therefore important. 📅 3️⃣ When Are Taxable Directors’ Fees Recognised?Where directors’ fees are taxable in Singapore, they are generally treated as income for the Year of Assessment in which the director becomes entitled to the fees. This is not necessarily the date when the money is actually paid. Entitlement will commonly arise when the fees are formally approved—for example: At the company's Annual General Meeting (AGM); orWhen the fees are approved by the company's board, depending on the company's circumstances. 🎯 Key TakeawayDirectors’ fees are generally sourced where the paying company is resident, so fees from a foreign company with no Singapore presence are generally not taxable in Singapore merely because board meetings are occasionally held there.However, remuneration for other duties physically performed in Singapore can be taxable. Where directors’ fees are taxable, the relevant income is generally recognised

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- Updated daily, we help 6, 7 and 8 figure International Entrepreneurs, Expats, Digital Nomads and Investors legally minimize their global tax burden and protect their wealth. - Join Amazon best selling author, Derren Joseph, in exploring the offshore financial world. Visit www.htj.tax

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    Offshore Tax with HTJ.tax