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REVOLUTIONARY shifts in the international tax landscape are afoot.
On Oct 5, 2021, the European Union (EU) endorsed commitments by Malaysia and other countries to reform their foreign-sourced income exemption (FSIE) regimes.
A few days later, the Organisation for Economic Co-operation and Development (OECD) updated its Two-Pillar Solution to address the tax challenges arising from the digitalisation of the economy (commonly referred to as BEPS 2.0), which promises to bring the most significant changes to international tax rules in over a century.
Despite its title, BEPS2.0 will impact all large multinational businesses and not just digital enterprises.
OECD’s BEPS 2.0 project
The OECD’s Two-Pillar Solution will result in profits of the largest multinational enterprises (MNEs) being reallocated to market jurisdictions for tax purposes.
Further, large MNEs will be subject to a minimum 15% global minimum tax rate from 2023.
Under Pillar One, a portion of profits derived by an MNE with global turnover exceeding €20bil (RM97bil) and a profit margin above 10% may be taxed in countries where their customers or users reside.
The turnover thresholds will be lowered to €10bil (RM48bil) in 2031.
This is a significant deviation from current tax rules, which generally only allow business profits to be taxed in locations where a company has physical presence. In contrast with countries with smaller populations such as Singapore and Hong Kong, Malaysia potentially stands to increase its tax revenue from this proposal.
On the other hand, with such high initial turnover thresholds and due to certain exclusions, Malaysian corporate groups are generally not expected to be impacted when Pillar One is implemented in 2023.
Pillar Two introduces a global minimum tax (GMT), set at 15% for groups with revenues of above €750mil (RM3.6bil).
Given the lower threshold relative to Pillar One, more MNEs, Malaysian groups included, will be impacted by Pillar Two.
In simple terms, under Pillar Two, parent entities can expect to pay a top-up tax on income of subsidiaries that are not subject to tax of at least 15%.
Malaysian subsidiaries of large MNEs that enjoy tax incentives typically pay concessionary tax rates far below 15% and may be impacted by the GMT.
Similarly, Malaysia-head-quartered groups that enjoy tax incentives or low tax rates overseas may be subject to a top-up tax in Malaysia.
Malaysia will need to rethink its approach to tax incentives and preferential tax regimes in light of the GMT.
Competition for foreign direct investment between countries will remain high, and we can expect to see creative solutions to meet increasingly bespoke incentive demands from investors.
To continue attracting investors, Malaysia will need to balance compliance with OECD recommendations with flexibility in its approach, and we expect to see non-tax incentives playing a more important role.