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the export ma, a company resident in Malaysia, manufactures electronic components for cost-effective macently, Visire Lid, an Indian company, discovered an innovative and Lid for
the export ma, a company resident in Malaysia, manufactures electronic components for cost-effective macently, Visire Lid, an Indian company, discovered an innovative and Lid for a technical kn to produce the same components. Omelett Sdn Bhd approached Visire demanded a royalty payment of RMS00. Mrykay, the founder of Visire Lid, later agreed and to be paid as follows: - RM150,000 is to be paid to Visire Ltd branch in Malaysia. - RM350,000 to be remitted to Visire Ltd in Singapore. As part of the agreement, Omelett Sdn Bhd is required to purchase a special equipment from Visire Ltd for RM1 million. To finance the acquisition. Omelett Sdn Bhd obtained a loan from a bank in Japan. The interest for the sum borrowed amounted to RM180,000 and is payable on 28 July 2021. Note: Ignore the provision of the Double Taxation Agreement Required: a. Explain with reason(s) whether each of the above payments is subjected to withholding tax (6 marks) b. Calculate the amount of withholding tax and penalty (if any) payable by Omelett Sdn Bhd to the Inland Revenue Board of Malaysia if the company remits the amount of withholding after the due date. (4 marks) c. Indicate with reason(s) whether each of the following situations constitutes a permanent establishment. i. Segar Meat Ltd, a Singaporean company plan to dosa its second branch in Johof Bahru and simply focus on its first branch in Plenang to distribute the company's meat products in the Malaysian market ii. Jauhar Ltd, a Paksstan-apparel based company planis to expand its business in Southeast Asia, particularly in Malay and Indanesia. The company decided to relocate its existing wanehouse in Dhaks to Kalimantan City. Indonesia
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