Malaysia’s Court of Appeal has confirmed that interest income derived by a taxpayer from loans made to an offshore entity is foreign-sourced and therefore not subject to Malaysian income tax.
Both taxpayers and officials need to change their approach to tax transparency if they are to ensure greater compliance and reduce exposure to tax disputes.
China has collected its largest-ever circular 698 tax demand on an offshore indirect transfer, fuelling concerns that officials are hardening their approach to compliance by foreign taxpayers.
Last week HMRC finalised its litigation settlement strategy (LSS) and alternative dispute resolution (ADR) guidance. International Tax Review speaks to Val Hennelly, HMRC’s head of dispute resolution about what this means for taxpayers involved in disputes.
