The DBA imposes double taxation when income is taxed in the two contracting states. In the case of Malaysia, Singapore tax due on Singapore`s income can be considered a credit in relation to Malaysian tax payable for those incomes. The Malaysian tax due on Malaysian income is accepted as a tax credit payable for these incomes in Singapore. The credit thus granted must not exceed the tax calculated before the transfer of credit by the country concerned. For the calculation of solvency, the tax payable does not take into account the specific exemptions, exemptions or subsidies granted by the respective jurisdictions and takes into account the taxable tax payable in the absence of such exemptions and reductions. In the case of dividends paid by a Singaporean company to a Malaysian company or a resident company holding at least 10% of the voting rights in the paying company, Malaysia takes into account the Singapore tax payable by that company for its income on which the dividend is paid, but the credit must not exceed the portion of the Malaysian tax. , as calculated before credit was granted. Accordingly, in the case of a Singapore beneficiary, a credit equal to the Malaysian tax that the company must pay for its income for which the dividend is paid is taken into account. Businesses that make payments of the following types of income are required to withhold tax at the rates shown in the table below. See note 5 for other sources of revenue submitted to the WHT. Profits of a business in a contracting state are taxable only in that state, unless the company operates in the other contracting state through a business management activity located there. But only the portion of the profit actually attributable to the MOU can be taxed in the other contracting state. In determining the benefits of the MOU, all expenses and deductions that would reasonably be attributable to the MOU and deductible are admitted if the MOU was an independent business and if the EP`s profits are determined to be a separate and distinct business that carries out the same or similar activities under identical or similar conditions and is totally independent of the business.
Of which he is the pe. The mere purchase of goods or goods by an MOU for the company does not have the effect of attributing profits to this MOU.