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Benta Sdn Bhd is a company resident in Malaysia and a Malaysian incorporated company for Malaysian tax purposes. The company source of income is solely

Benta Sdn Bhd is a company resident in Malaysia and a Malaysian incorporated company for Malaysian tax purposes. The company source of income is solely from manufacturing operations conducted from a factory in Batu Berendam, Melaka. Benta Sdn Bhd is a wholly-owned subsidiary of Berry Ltd, a company incorporated in Belgium. For the year ended 31 January 2014, Berry Ltd granted Benta Sdn Bhd a loan to finance its manufacturing operations. The total interest payable to Berry Ltd amounted to RM82,930 and the payment was charged to the income statement of Benta Sdn Bhd. Required: State, with reasons, whether the interest payment of RM82,930 is derived from Malaysia. Explain how and how much it would be taxed (if applicable) under the Section 109 of the Income Tax Act, 1967.

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