Just read this on the Singaporean Straits Times.
In the meantime, I get a reply via email from the IRB that reads like this…
I would just like to clarify my opinion re the above given this morning.
The activity of the recipient in his country is irrelevant in determining whether the income it receives is sec 4(f) income or not. Malaysia cannot / will not decide whether the activity of the recipient is a business activity as it doesn’t fall under the jurisdiction of ITA 1967. If the payment made by resident person is the type of gains or profits which falls under sec 4(f) and sec 15B, then section 109F is applicable. Thus any confirmation re its activity (the NR) will be irrelevant for this purpose.
I truly regret the incorrect or misleading advice given this morning.
And THAT, ladies and gentlemen, is the difference between us and them.
