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IRBM’s Response to CTIM on e-C 2022 (3)

Updated: Nov 4, 2022


Regarding Form e-C 2022, CTIM has offered feedback and comments to the Inland Revenue Board of Malaysia (IRBM).


The Inland Revenue Board of Malaysia issued its response on 29 July 2022 and 2 August 2022, respectively.


Despite this, on 11 August 2022, CTIM provided IRBM with additional feedback and comments on the form e-C 2022 after IRBM's responses were provided.


The IRBM issued their responses on September 9, 2022, to the following sections of Form e-C 2022 mentioned in the CTIM Additional Feedback and Comments on 11 August 2022.


Issue No 1: Item A2 and A7 - Disclosure in the Form e-C relating to Foreign Source Income

1.1 Referred to the "Summary of Statutory Income from sources of business(es) and partnership(s) outside Malaysia received in Malaysia starting from 1 July 2022."



Currently, the TAeF allows disclosure of 1 country under 1 business source only.


How do the taxpayers disclose the information in a situation where the foreign source income (FSI) is from multiple countries in one business source (e.g., Business 1)’?


IRBM's response on 2 August 2022:

Income reporting should be done separately by the country. For e-Filing, the system allows the use of the same business code for each reporting business income from different countries.

A2 of the e-Form C 2022 (i.e., Summary of statutory income from sources of business(es) and partnership(s) outside Malaysia received in Malaysia effective from 1 July 2022)

CTIM additional feedback and comments on 11 August 2022:

Based on IRBM’s response above, CTIM notes that the system allows the same business code for different countries. However, Form e-C only allows disclosure of 1 business source for 1 country.


IRBM's response on 9 September 2022:

Income from similar activities from the same country should be combined and reported in the same row and space. Income segregation for the same business code from the same country does not need to be done for FSI reporting in e-C 2022.


CTIM additional feedback and comments on 11 August 2022:

Based on the A2 of the e-Form C 2022 (i.e., Summary of statutory income from sources of business(es) and partnership(s) outside Malaysia received in Malaysia effective from 1 July 2022), the e-Form C 2022 system seems to have not been updated to allow disclosure of foreign business income for more than 1 country under 1 business source.


As extracted below, it appears that row 2 has been fixed as Business 2, row 3 as Business 3, and so on.

CTIM would like to seek further clarification from IRBM on whether:-

  • IRBM will update its system to allow taxpayers to select “business identification” manually, or

  • As long as the taxpayers inserted the same business code in different rows, the IRBM will take these disclosures as foreign business income under 1 business source (even though the business identification column does not match).


IRBM's response on 9 September 2022: Taxpayers can use the same business code for each country concerned on different rows to indicate companies doing the same business in those countries.


The proposal from CTIM will be considered when designing e-C for the subsequent assessment year.


CTIM additional feedback and comments on 11 August 2022:

Example: ABC Sdn Bhd has two business sources:

  1. providing engineering services and

  2. trading machines.

ABC Sdn Bhd has branches in Singapore and Hong Kong that provide the same engineering services.


In YA 2022, the following information is available for the Form e-C disclosure:

Based on the example given above, can IRBM guide how the “Summary of statutory income …. In Malaysia” and the “Summary of Statutory Income from sources …. received in Malaysia from outside Malaysia” be completed?


IRBM's response on 9 September 2022:

Based on the limited information above, the following are general guidelines for reporting in e-C 2022:

  1. The statutory income of business 1 in Malaysia is reported in column A1 and appendix A1 respectively.

  2. The statutory income of business 1 in Singapore and Hong Kong is reported either in column A2 and appendix A2 or column A 20 and appendix A20 depending on when the income is remitted. This reporting is subject to the business income in Singapore and Hong Kong having been taxed in those countries.

  3. Interest income from Singapore and Hong Kong must be reported in either column appendix A7 and appendix A7 or columns A 20 and appendix A20, depending on when the income is remitted.

The ultimate tax reporting and calculation will be determined by the relevant circumstances in connection with:

  • the management of company activities,

  • the date of remittance of income sourced outside of Malaysia, and

  • the income tax status in the place of origin.

1.2 Capital Allowance disclosure

CTIM additional feedback and comments on 11 August 2022:

Using the same example above –

  • How does a taxpayer complete Item C1a (Attachment) of Form e-C for YA 2022?

  • If the remaining portion of the FSI is received in Malaysia in YA 2023, how does a taxpayer complete Item C1a (Attachment) in Form e-C for YA 2023?

  • Only a portion of the statutory FSI is received in Malaysia in YA 2022. In this case, how do we disclose the amount of the CA utilised (absorbed) under Item C1a (Attachment) of Form e-C for YA 2022?

IRBM's response on 9 September 2022:

The disclosure of information regarding capital allowances in schedule 3 of appendix C1a for form e-C2022 is only required if the business income was derived from Malaysia (referring to column and Appendix A1).


Issued No 2: Item A20 - Income from sources outside Malaysia received in Malaysia for the period from 01.01.2022 to 30.06.2022 [If 7 = MY]


CTIM additional feedback and comments on 11 August 2022:


Referring to IRBM's response on 2 August 2022 (as follows), it appears that a direct translation of the sentence means "the FSI received in Malaysia shall refer to the gross amount".




Kindly confirm that the actual FSI remitted shall be taken as the gross income instead, i.e., there is no requirement to re-compute the gross income of which the FSI is remitted into Malaysia.


IRBM's response on 9 September 2022:

There is no need to re-compute the remitted income because it is gross income based on the provisions of Section 6, Part XX of the ITA 1967.


Issue No 3: Part E - Summary of losses for business and partnership that are subject to restriction under Section 44(5F)

Previously, this section was used to report normal business and pioneer losses with the heading of the appendix: Summary of Losses (Including Pioneer Losses after tax relief period).