Malaysia Tax Agency Issues Decree Clarifying Group Relief Rules for Corporate Tax Loss Transfers

The Malaysian Inland Revenue Board July 31 issued General Decree No. 2/2025, clarifying group tax relief for companies incorporated and resident in Malaysia. Topics covered include: 1) the ability to transfer up to 70 percent of a group company’s losses for deduction by one or more companies in the same tax group; 2) qualifications for related companies based on shareholding and beneficial entitlement to profits and assets; 3) clarification that transferring losses is only allowed for new companies in their first three years of operation; 4) calculation rules for group relief, including surrender limits, priority of claims among group companies, ...