Tuesday, 13 January 2015

Sec 21A Basis period

How to Determine the Tax Basis Period for a Company?
Why it is important to determine the basis period for a company?
There are generally 2 reasons:-
-          Tax law compliance
-          To do with “Deduction”. Usually pre-commencement expenses are not deductible.

The basis period of a company, limited liability partnership, trust body or co-operative society has been defined in Section 21A of Income Tax Act 1967.

Section 21A (3) of Income Tax Act 1967  [Effective from year of assessment 2014]

Presently, it is provided in Section 21A(3) of the Income Tax Act 1967 that, where a company, limited liability partnership, trust body or co-operative society has made up the accounts of its operations for a period of twelve months ending on a day in a basis year and there is a failure to make up accounts of the company, limited liability partnership, trust body or co-operative society ending on the corresponding day in the following basis year, the Director General may direct that the basis period for the year of assessment in which the failure occurs, or the basis periods for that year and the following year of assessment, shall consist of a period or periods (which may be of any length) as specified in the direction.

However, no legislation exists (apart from the public rulings issued by the Inland Revenue Board) to govern the basis periods for the relevant years of assessment for the same failure which applies to a company, limited liability partnership, trust body or co-operative society that normally makes up the accounts for a period of 12 months ending on 31 December.

History
Subsection 21A (3) is amended by Act 761 of 2014 para 8(a), by substituting for the words "other than 31 December" the words "in a basis year", has effect for the year of assessment 2014 and subsequent years of assessment.

Likely Tax Effects and Implications
The above proposal enables the Director General to direct the basis periods of all companies, limited liability partnerships, trust bodies or co-operative societies that change their accounting year end.

Illustration:
(Dates used in examples has ignored the effective date of Subsection 21A (3) of ITA 1967)

Examples
Accounting Period
Basis Period
Remarks
ABC1 Sdn Bhd made up its account from 1 May 2010 to 30 April 2011, subsequently it has changed its accounting period ended from 1 May 2011 to 30 June 2012, thereafter to 30 June each year.
1 May 2010 to 30 April 2011

1 May 2011 to 30 June 2012

1 July 2012 to 30 June 2013
1 May 2010 to 30 April 2011 (YA2011)

1 May 2011 to 30 June 2012 (YA2012)

1 July 2012 to 30 June 2013 (YA2013)
The tax basis period will follow the accounting period as the “continuity of year of assessment” is present. ie YA2012, Ya2013 & YA2014.
ABC2 Sdn Bhd made up its account from 1 July 2010 to 30 June 2011, subsequently it has changed its accounting period ended from 1 July 2011 to 31 December 2011, thereafter to 31 December each year.
1 July 2010 to 30 June 2011

1 July 2011 to 31 December 2011

1 January 2012 to 31 December 2012
1 July 2010 to 30 June 2011 (YA2011)

1 July 2011 to 31 December 2012 (YA2012)


Both accounting periods was added together as one tax basis period as its year end (ie. 31 December 2012) is coincident with YA2012.
ABC3 Sdn Bhd made up its account from 1 January 2012 to 31 December 2012, subsequently it has changed its accounting period ended from 1 January 2013 to 31 March 2014, thereafter to 31 March each year.
1 January 2012 to 31 December 2012

1 January 2013 to 31 March 2014


1 January 2012 to 31 December 2012 (YA2012)

1 January 2013 to 31 August 2013 (YA2013)

1 September 2013 to 31 March 2014 (YA2014)

Accounting period ended 31 March 2014 has “jump from 2012 to 2014”, it has “skipped” the year 2013 and therefore need to split the accounting period for tax basis period determination. The period consists of 15 months, 8 months allocated to YA2013 and 7 months allocated to YA2014.

Section 21A (4) Income Tax Act 1967 [Effective from year of assessment 2014]

With the intention of providing more clarification to the existing legislation, it is proposed that, subject to subsections (5) and (6), where a company, limited liability partnership, trust body or co-operative society commences operation on a day in a basis year for a year of assessment (hereinafter referred to as the "first year of assessment") and makes up its account:-

(a) for a period of less than twelve months ending on a day in that basis year, that period shall constitute the basis period for the first year of assessment;

(b) for any period of months ending on a day in the immediately following basis year (hereinafter referred to as the "second basis year"), that period shall constitute the basis period for the year of assessment (hereinafter referred to as the "second year of assessment") immediately following the first year of assessment, there shall be no basis period in relation to any of its sources of income for the first year of assessment; or

(c) for a period of more than twelve months ending on a day in the basis year immediately following the second basis year, that period shall constitute the basis period for the year of assessment immediately following the second year of assessment and there shall be no basis period in relation to any of its sources of income for the first year of assessment and the second year of assessment.

History
“Subsection 21A(4) is substituted by Act 761 of 2014, has effect for the year of assessment 2014 and subsequent years of assessment.

The previous Section 21A(4) of the ITA 1967 state that, where a company, limited liability partnership, trust body or co-operative society commences operations on a day in a basis year and makes up its accounts for a period of twelve months ending on a day other than 31 December, there shall be no basis period in relation to any of its sources of income for the first year.

However, the provision is silent on the determination of the basis periods for those cases where the accounts are made up for a period of less than or more than twelve months. As a result, references are sought to the relevant public rulings issued by the Inland Revenue.

Likely Tax Effects and Implications
The above proposal is intended to simplify the determination of the first basis period of a company, limited liability partnership, trust body or co-operative society upon its commencement of business operations. With the above proposal, the issues of overlapping basis periods, apportionment of adjusted business income or loss, and submission deadlines of tax returns and estimates of tax payable can be mitigated.

Illustration:

ITA 1967
Examples
Accounting Period
Basis Period
Remarks
Sec
21A(4)(a)
ABC Sdn Bhd commences its business on 1 May 2013 and made up its account to 30 November 2013, thereafter to 30 November each year.
1 May 2013 to 30 November 2013

1 December 2013 to 30 November 2014
1 May 2013 to 30 November 2013 (YA2013)
1 December 2013 to 30 November 2014 (YA2014)

Sec 
21A(4)(b)
DEF Sdn Bhd commences its business on 1 May 2013 and made up its account to 31 March 2014, thereafter to 31 March each year.
1 May 2013 to 31 March 2014

1 April 2014 to 31 March 2015
1 May 2013 to 31 March 2014
(YA2014)
1 April 2014 to 31 March 2015 (YA2015)
There will be no basis period for the first year of assessment. ie YA2013
Sec
21A(4)(c)
GHI Sdn Bhd commences its business on 1 November 2013 and made up its account to 31 January 2015, thereafter to 31 January 2015.
1 November 2013 to 31 January 2015

1 February 2015 to 31 January 2016
1 November 2013 to 31 January 2015 (YA2015)

1 February 2015 to 31 January 2016 (YA2016)
There will be no basis period for the first and second year of assessment. ie YA2013 and YA2014

Do you know what is the meaning of “Commencement date”? 

Section 21A(5) of the ITA 1967 states that, where a company commences operations and

(a)   is required under any law of the place of incorporation to make up its accounts ending on a   specified day; or
(b)   being a company within a group of companies makes up its accounts ending on the same day as that of all other companies in that group,

the period which begins from the day the company commences operations until the end of the accounting period of the company shall constitute, for those operations of that company, the basis period for a year of assessment.

However, the “actual date” of the commencement date of a business is not specified in the Law. It is important to define the “actual date” of the business commencement date because of the pre-operating expenses are not deductible. A business is said to be commenced if its integral activity was carried out.

What is the basis period for persons other than company, limited liability partnership, trust or co-operative society?
It must be always the calendar year as the basis year (ie 1 January to 31 December).

Reference:
http://www.hasil.gov.my/pdf/pdfam/Section_21A.pdf



Disclaimer

The information provided in this blog is based on taxation laws and other legislation, as well as current practices, including legislative proposals and measures contained in the 2014 Malaysian Budget announced on 25 October 2013
This booklet is intended to provide a general guide to a subject matter and should not regarded as a basis for ascertaining the liability to tax in specific circumstances. No responsibility for loss to any person acting or refraining from acting as a result of any material in this publication can be accepted by YapSupremeServices. Recipients should not act on the basis of this publication without seeking professional advice.

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