Kumpulan 5 - Report Case 2 (AP Cars SDN BHD)

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EPPA 4716

KAJIAN KES INTEGRASI

TITLE:
CASE 2 – AP CARS SDN BHD

LECTURER’S NAME:
DR. ROSIATI BT. RAMLI

PREPARED BY:
GROUP 5

NOR ASYIRAH BINTI ABDUL AZIZ GA04058


NOR’ AIN BINTI ABDULLAH GA04061
NUR AZILA BINTI ABDULLAH GA04065
NUR FAIRUEZ BT RAJAB GA04066
FATIN HAFIZAH BINTI AMRAN GA04346
ACKNOWLEDGEMENT

First and foremost, we are very grateful to be able to prepare this report successfully. We would
never be able to finish research without the guidance from the lecturer, help from friends and
support from our family. A very thankful to Allah for answering our prayers for giving us
strength plods on despites my constitution wanting to give up and throw in the towel.

Secondly, we also would like to express our highest appreciation and thankfulness to
our lecturer, Dr. Rosiati Bt. Ramli for her excellent guidance, caring, patience and providing
us with an excellent atmosphere to complete this report. It should be noted that the knowledge
we received really helped us while completing this project. Within her kind direction and
proper guidance towards this project to be completed perfectly. Big thanks to all my friend
members who always shared opinions and experience among us and gave a clear idea to
complete this report. We also would like to acknowledge the parties that are helping us in
preparing our report either directly or indirectly.

Finally, special thanks to our parents and family who always support and give advice. Without
their encouragement, we would not have to finish this project.
Table of Contents

CHAPTER 1 INTRODUCTION ............................................................................................ 4

1.1 Tax Evasion ................................................................................................................. 4

1.2 Tok Mat – Car Dealers ................................................................................................ 5

CHAPTER 2 PERSPECTIVE MR AHAD – TAX ADVISOR ............................................ 6

2.1 Introduction ................................................................................................................. 6

2.2 Calculation of Income and Expenses Tok Mat ........................................................... 7

2.3 Strategies Tax Advisor to help Tok Mat ..................................................................... 8

CHAPTER 3 PERSPECTIVE FROM MINISTRY OF INTERNATIONAL TRADE


AND INDUSTRY (MITI) AND ROYAL MALAYSIAN CUSTOMS DEPARTMENT . 10

3.1 Introduction ............................................................................................................... 10

3.2 Perspective MITI for Tok Mat cases ......................................................................... 11

3.3 Perspective Royal Malaysian Customs Department ................................................. 12

CHAPTER 4 PERSPECTIVE INLAND REVENUE BOARD MALAYSIA (IRBM) .... 13

4.1 Introduction ............................................................................................................... 13

4.2 Section and penalty based on Tok Mat cases: ........................................................... 13

4.3 Tax Investigation by IRBM....................................................................................... 14

4.4 Findings by Special Commissioner of Income tax (SCIT) ....................................... 17

CHAPTER 5 ANTI MONEY LAUNDERING ACT (AMLA) .......................................... 18

5.1 ANTI MONEY LAUNDERING ACT (AMLA) ...................................................... 18

CHAPTER 6 HIGH COURT’S LEVEL.............................................................................. 19

6.1 Facts of Cases ............................................................................................................ 19

6.2 Issue in Tok Mat cases: ............................................................................................. 19

6.3 The High Court’s Decision ....................................................................................... 20

CONCLUSION ...................................................................................................................... 21

REFERENCE ......................................................................................................................... 22

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CHAPTER 1

INTRODUCTION

1.1 Tax Evasion

Tax evasion is an unlawful act in which the entity or person knowingly misrepresents
circumstances to reduce actual tax liabilities and includes false tax reporting, such as showing
less income, profit or profit than actually earned and exaggerating cutting.

Tax evasion is different from tax avoidance. When a person acts illegally to avoid
paying taxes, then it is said to be tax evasion. Whereas when a law is used for benefits in a way
that was not originally intended by the law, to reduce tax liabilities is referred to as tax
avoidance. This is when someone takes illegal steps to avoid paying taxes. Often produces
other consequences.

Tax evasion is a crime in which an entity or individual intentionally evades payment


or pays taxes. Every citizen who generates income and or assets is required to submit an income
tax return annually. Too many people each year give a wrong impression of the amount of
money earned, and they claim wrong or excessive deductions, which are not allowed in an
effort to keep money away from the IRBM. In the USA, the government estimates that about
USD 350 billion is lost each year due to tax evasion practices. Taxpayers should avoid it to
save themselves from any punishment.

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1.2 Tok Mat – Car Dealers

Tok Mat had set up a company under his name and opened a bank account in the company’s
name. He gave permission to Mr Lim to use his AP, and Mr Lim operated his bank account
and company name using Tok Mat’s AP. Tok Mat had asked Mr Lim to help him to manage
the company but what he did, letting Mr Lim the power to use his AP, was against the law.

Tok Mat was approached by the Inland Revenue Board of Malaysia (IRBM), the
Royal Malaysian Customs Department, the Attorney General, AMLA and the Malaysian Anti
-Corruption Commission (MACC) for interrogation. Tok Mat was accused of tax evasion and
abusing an import license also known as an Approved Permit (AP). IRBM asked Tok Mat to
submit a capital statement for income tax purposes, but Tok Mat never kept all receipts and
invoices of each transaction and does not record expenses and income for his company.

Tok Mat had to pay income tax of RM 9 million in 2011. In 2001 - 2003, Tok Mat
needed to pay about RM 2.5 million, since Tok Mat was convicted, he only paid RM 500,000.
Therefore, RM 2.5 million will be added to the total penalty and thus is the amount of tax to be
paid. Tok Mat seeks help from Ahad (tax advisor) to assist him from being charged with lawsuit
by relevant parties.

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CHAPTER 2

PERSPECTIVE MR AHAD – TAX ADVISOR

2.1 Introduction

Mr Ahad made a statement regarding the tax offense committed by Tok Mat.

Tax evasion is a criminal offense that involves deliberately misinterpreting the actual state of
affairs of the person to the tax authorities to reduce their tax liability and includes dishonest tax
reporting, such as declaring less income, profit or gain than the amount actually earned, or
excess deduction.

Pursuant to the Income Tax Act 1967, Para 114 to evade, any person who knowingly and with
intent to evade or assist any other person to evade tax consist of:

i. Non-refundable from any income made under this Act,


ii. Making false statements or entries in returns made under this Act.
iii. Giving false answers (orally or in writing) to questions asked or requesting
information made pursuant to this Act.
iv. Provides or maintains or authorizes the preparation or maintenance of false books of
accounts or other false records.
v. Falsifying or authorizing the falsification of books of account or other records.
vi. Using or authorizing the use of any fraud, art or equipment.

Tok Mat needs to submit a capital return for income tax purposes. However, Tok Mat is not
someone who keeps all receipts and invoices. In order for his tax agent to prepare a capital
statement, Tok Mat needs to show his tax agent all his assets and liabilities. This also includes
the assets and liabilities of the Tok Mat spouse and minors. Assets here means all bank deposits,
including cash, investments in negotiable instruments, investments in related entities, current
accounts maintained with related parties, immovable property, vehicles, jewelry as well as
furniture, fittings and other assets.

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2.2 Calculation of Income and Expenses Tok Mat

Before making an appeal, Mr Ahad made an estimation for income and expenses of Tok Mat
from 2000 to 2011. Below is the estimation for transaction Tok Mat:

2.2.1 Income Statement (Estimation)

2.2.2 Estimation Penalty rate of Tok Mat 2003 – 2011)

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2.3 Strategies Tax Advisor to help Tok Mat

After making the calculation, Mr Ahad advised Tok Mat, Based on Section 107 (B), every
person taxed for each year, other than companies, trust bodies, cooperatives shall make
payment in installments based on tax, excluding tax on profits and gains of a job, at that time
and amount. According to this case, Tok Mat can make a payment of RM 9 million in
installments.

If Tok Mat is unable to pay the fine, Tok Mat can appeal to pay in installments.
Therefore Section 99 of the ITA 1967 only applies to appeals against notices of assessment
made for any year of assessment for the following cases:

i. Assessment or additional assessment or advance assessment made by the DGIR as a


result of desk audit findings or external audit; or
ii. The best judgment assessment made without ITRF or ITRF is submitted late, i.e.,
outside the period prescribed under subsection 90 (3) of the ITA 1967.

An appeal shall be made by submitting Form Q not later than thirty (30) days after the notice
of assessment is submitted as provided under subsection 99 (1) of the ITA 1967.

Figure 1 Form Q

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Tok Mat can apply for a late appeal by submitting Form N. The Appellant needs to submit
Form N strong reasons for the application for extension of time.

Figure 2 Form Q

One of the reasons that can be considered is circumstances beyond the appellant's control for
example; appellant was hospitalized for a long period of time, was abroad, was involved in a
natural disaster or other reasonable and lawful reasons. But, Tok Mat did not have a strong
reason to apply for a late appeal besides not having supporting documents except bank
statements. Mr Ahad suggested Tok Mat to follow the procedure suggested by LHDN for the
next step.

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CHAPTER 3

PERSPECTIVE FROM MINISTRY OF INTERNATIONAL TRADE AND

INDUSTRY (MITI) AND ROYAL MALAYSIAN CUSTOMS DEPARTMENT

3.1 Introduction

Approved permit is one of the import licenses that has been Permit Issuing Agencies (PIAs)
under Custom Act 1967. The Ministry of International Trade and Industry (MITI) made an
announcement on implementing New Open AP Policy on December 23, 2015. This new policy
proposes focusing on three (3) major targets which is providing the opportunity to new
Bumiputera entrepreneurs to participate in the automotive industries. The Edge Market
reported, MITI postponed the new policy for almost two years due to uncertainties in the
domestic automotive market on January 1, 2019 instead of January 1, 2017.

Three (3) main purposes that have been highlighted in Open Approved Permit (AP)
are more competitive in the industries, this policy gives more advantage especially for
consumers to have more choice. Secondly, give an opportunity to Bumiputera to increase their
social economies, besides giving opportunities to other entrepreneurs in the automotive
industries. On top of that, Open AP could give more positive growth to the economy.

Improvement that has been done from previous AP, involved in three main points
which is strictly term and condition requirement, penalize any company against the requirement
and fi and compound on Open AP. There are conditions needed to be followed by companies
if they want to Open AP in new regulations. Company that has an intention to apply Open AP
is must title as Bumiputera status which is applicable if it is hundred percent own by
Bumiputera, Board of Director, Position of Chief Executive, Managing Director or General
Manager, Branch Manager, Marketing/Sales Manager control by Bumiputra. Management on
financial either on transaction and cheque signature must be Bumiputera.

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3.2 Perspective MITI for Tok Mat cases

As our discussion regarding Tok Mat case in the perspective MITI, as an article stated as below:

“Mr. Lim has his own car business, Lim Kar Sdn Bhd. Mr Lim said, all I had to do was set up
a company in my name and open up a bank account in the company’s name. But the bank
account will have him and his partner as the signatories. He will be putting in the money into
the account to buy the cars from Europe and Japan. He said he needed to use my company bank
account as all transactions must be in my company name, he can’t use his company. Mr Lim
said that for every car he buys and sold, he will give me RM30,000. So that’s what I’ve done.
I set up AP Cars Sdn. Bhd. and opened a bank account with Public Bank. Every month Mr.
Lim will take the money out of Public Bank and deposit it into my personal account at CIMB”
and “Mr Lim is the one who signs the cheques” - said Tok Mat.

As scenarios above we can clearly know Tok Mat against the terms and conditions for
Open AP which is made by Mr Lim who is the person who manages all finance such as import
transactions made by Mr. Lim and his partner, Tok Mat, were not aware they cannot do this
transaction because they do not have agreement between them. On Top of that, Mr Lim and his
partner are the signatories for the AP Cars Sdn Bhd bank cheque. Moreover, the most crucial
part in AP application is a person who applies for this AP must have Bumiputera status. But as
we know Tok Mat has breached one of the conditions of AP because Tok Mat involved Mr
Lim in arranging his transaction. It means the bank account of Tok Mat will have Mr Lim and
his partner as the signatories. Besides every car sold, Tok Mat will receive RM 30,000. Tok
Mat action will affect his AP licence which is MITI will withdraw or suspend the allocated and
approved AP, blacklisting the companies (including every shareholder and board member of
the company) from submitting any future application on Open AP and taking a legal action
against the company.

Moreover, MITI announced on March 13, 2019 the company has been blacklisted
because of 9 existing companies for offenses not complying with the conditions. Currently in
November 2021, 177 companies are entitled for AP licence compared to 128 when their first
year implements on January 1, 2019. In MITI opinion Tok Mat did not comply the mandatory
condition which is his financial management was managed by Mr. Lim and bank cheque sign
by Mr. Lim and his partner. Besides, Tok Mat did not have any agreement between his partner.
MITI will withdraw or suspend the allocated and approved AP, blacklisting Tok Mat company.
Moreover, another condition that must be met is that all the companies should operate their

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own company without using third parties either to import or sell it, another thing is car display
and garage or storage for imported cars must be in the premises if the company has an AP
license. These two main reasons are such strong evidence that To Mat breaches the condition
and he is aware and knows about it.

3.3 Perspective Royal Malaysian Customs Department

Furthermore, from The Customs Department all the imported cars must have an imported
license which is an AP license that is one of the mandatory requirements on top of that all the
cars must declare in the Custom Form No. 1 (K1) and tax in the customs clearance.

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CHAPTER 4

PERSPECTIVE INLAND REVENUE BOARD MALAYSIA (IRBM)

4.1 Introduction

Inland Revenue Board of Malaysia (IRBM) officers have carried out their duties to investigate
Tok Mat. A tax investigation usually begins with a surprise visit to the taxpayer’s business
premises, personal residence, agent or representative and the premises of various third parties
to possess the documents and books of account required for the purpose of the investigation.
The purpose of the tax investigation on Tok Mat is to investigate taxpayers suspected of being
involved in fraud, wilful fraud or negligence in reporting their income.

4.2 Section and penalty based on Tok Mat cases:

Based on Tok Mat cases, Tok Mat can be penalized based on Section 112(1), 114(1) and 119A.
Below is the detailed fine needed to pay by Tok Mat if the Court agrees with facts found by
Special Commissioners of Income Tax (SCIT).

Type Of Offences Provisions Amount Of Fine (RM)


Under ITA
1967

Failure (without reasonable excuse) 112(1) 200.00 to 20,000.00 /


to give notice of chargeability to tax. Imprisonment for a term not
exceeding 6 months / Both

Wilfully and with intent to evade or 114(1) 1,000.00 to 20,000.00 /


assist any other person to evade tax. Imprisonment for a term not
exceeding 3 years / Both and
300% of tax undercharged

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Fails (without reasonable excuse) to 119A 300.00 to 10,000.00 /
comply with an order to keep proper Imprisonment for a term not
records and documentation. exceeding 1 year / Both

Fails (without reasonable excuse) to 120(1) 200.00 to 20,000.00 /


comply with a notice asking for Imprisonment for a term not
certain information as required by exceeding 6 months / Both
IRBM.

Fails (without reasonable excuse) to 120(1) 200.00 to 20,000.00 /


give notice on changes of address Imprisonment for a term not
within 3 months. exceeding 6 months / Both

4.3 Tax Investigation by IRBM

The Inland Revenue Board of Malaysia (IRBM) has assigned their officers to conduct an
investigation into Tok Mat, the owner of AP Cars Sdn Bhd. IRBM officers performed a tax
investigation in Tok Mat cases. The main purpose of their visit was as a representative of the
IRBM who had suspected that there were elements of tax evasion committed by Tok Mat.

The officer on duty explained to Tok Mat that he can be charged under Section 79 and Section
81, Income Tax Act 1967, the power to get bank statements and other related documents. The
Director General may by notice under his hand require any person to give within the time
specified in the notice (not less than thirty days from the date of service of the notice) a
statement containing particulars: -
a. All banking accounts-
i. in his own name or in the name of his wife or dependent children or jointly in
any such name;
ii. in which he has or has an interest jointly or solely; or
iii. where he has or has the power to operate jointly or solely.

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It is the right to direct Tok Mat to submit the Capital Statement within 30 days from the date
of service of this notification if the IRBM is of the opinion that there is tax evasion committed
by the taxpayer.

Figure 3 Capital Statement

The IRBM has recommended Tok Mat to use the services of an experienced Tax Agent (Encik
Ahad) because a review found that Tok Mat has an Approval Permit (AP) license with an
income of RM30,000 for one AP and Tok Mat can received until reached 100 units of car every
year. In between the issues Tok Mat had not reported his income and had not paid taxes, so the
board required his documents related with incomes, expenses, assets, liabilities, capitals and
other related documents to review. Therefore, the IRBM will use Form C.P 102 (Capital
Statement) to report Tok Mat and his independent assets and liabilities for the Year of
Assessment 2000 to 2003 and for the Year of Assessment 2004 to Year of Assessment 2011.

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Figure 4 Form CP102

IRBM also issued Form C.P 103 (Personal Expenditure Statement) to be completed by Tok
Mat. Tok Mat needs to provide documents needed in C.P 103 together with his independents
for the Year of Assessment 2000 until 2003 and Year of Assessment 2004 until 2011. Also, if
Tok Mat has any business located anywhere either in the name of Tok Mat or the name of an
individual nominated by Tok Mat need to be reported. The IRB officer assigned in the Tok Mat
investigation, reminded not to forget to return Form C.P 102 and Form C.P 103 within 30 days
from the date the letter and form were submitted to Tok Mat. Other information on IRBM
policies will be communicated by other IRBM officers.

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4.4 Findings by Special Commissioner of Income tax (SCIT)

Tok Mat needs to pay debt based on suggestions by IRBM together in 2000 with Form Q to
apply for appeal based on Section 2A (1) and (2) Income Tax Act (ITA) 1967. If Tok Mat did
not agree to suggestions by IRBM, he needed to argue before paying RM 500 thousand.
Supposedly, Tok Mat can have a discussion with IRBM regarding his income tax and he can
be asked to make an instalment to settle his debt with IRBM. It showed he agreed to the amount
suggested by IRBM because there was no argument or discussion between Tok Mat and IRBM.
Tok Mat who retired as a Custom Officer must be aware his income can be taxed and he has
knowledge regarding tax income. Based on investigation, SCIT found that Tok Mat was not
aware of the risk that would exist when he did not pay tax income. This is because every person
who can be taxed needs to keep 11 documents, especially related income and expenses for at
least 7 years. Tok Ahmad did not keep his documents and maybe he thinks the possibility of
being trapped by the IRBM is slim. There was no effort from Tok Mat since his last payment
and this is the second time for IRBM to take action towards Tok Mat since his debt reached
RM 9 milion in 2011. Tok Mat asked En Ahad, who is a tax advisor, to solve his cases. But,
his tax advisor can only make an estimation without any supporting documents except bank
statements.

Moreover, payment from Mr Lim RM 30,000 is considered illegal because there is no


agreement between Tok Mat and Mr Lim regarding their partnership and cannot prove the
existence of partnership for income tax purposes. If they are a partnership, they must prove
participation in the capital or any significant event to show them as a partner. Tok Mat also did
not declare his income from Mr Lim was taxable. SCIT needs to value assets and liabilities of
Tok Mat and his independents based on CP102 (Capital Statement) and CP103 (Personal
Expenditure Statement). Results from the CP102 and CP103 showed there was no effort from
Tok Mat to settle his debt with IRBM and no appeal to pay debt in instalments. IRBM also can
bring these cases The Anti-Money Laundering, Anti-Terrorism Financing and Proceeds of
Unlawful Activities Act 2001 (AMLATFPUAA) based on Section 112, 113 and 114 ITA 1967.
After finishing the investigation, SCIT needs to refer Tok Mat cases to the legal department for
further action since he cannot pay debt and does not have intention to settle his cases within
the period given by IRBM. Therefore, Tok Mat still can make an appeal in the High Court after
judgement.

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CHAPTER 5

ANTI MONEY LAUNDERING ACT (AMLA)

5.1 ANTI MONEY LAUNDERING ACT (AMLA)

Money laundering is a process of exchanging cash or property derived from criminal activity
to give a legitimate appearance. It is a process of laundering ‘dirty’ money to disguise its
criminal origins. AMLA as a law enforcement agency, the IRBM can take preventive action,
detection and investigation of money laundering cases related to serious offenses.

The failure of the BNCP (section 112 of the ITA), making incorrect statements (section 113 of
the ITA) and the deliberate escape (section 114 of the ITA) are listed as serious offenses in the
Second Schedule of AMLATFPUAA. As a law enforcement agency, the IRBM can take
preventive measures, detection and investigation of money laundering cases related to serious
offenses. If convicted of money laundering under section 4 of the AMLATFPUAA, any person
may be imprisoned for not requiring fifteen years and may also be fined not related to five
times the amount or value of the proceeds of the illegal activity or equipment of the offense at
the time of the offense or Ringgit Malaysia Five Million (RM5,000,000.00), whichever is
higher.

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CHAPTER 6

HIGH COURT’S LEVEL

6.1 Facts of Cases

As per the High Court's judgement, the learned counsel will value these cases based on finding
of the facts by SCIT. SCIT found that Tok Mat, who collaborated with Mr Lim did not fulfil
elements of partnership. But, Tok Mat received RM 30,000 for each car from Mr Lim and did
not declare his income was taxable. IRBM asked Tok Mat to pay RM 3 million in 2003 but he
only paid RM 500,000 without any argument. Supposedly Tok Mat can follow procedure by
LHDN in 2003 with Form Q and Form N beside appoint tax advisor. But, Tok Mat did not
meet the IRBM officer and IRBM considered Tok Mat agreed with the amount needed to be
paid in 2003. After paying RM 500,000 Tok Mat did not pay the balance until 2011 and IRBM
sent SCIT to make an investigation. This is because Tok Mat does not make an effort to follow
up with IRBM to settle his debt. As a taxpayer, he needs to keep related documents for tax
purposes but he does not keep them. Tok mat who is retired as a Custom Officer must have
knowledge regarding income tax and must know the procedure to be followed. Tok Mat's action
has shown that he is in the phase of tax evasion.

6.2 Issue in Tok Mat cases:

6.2.1.1 Will taxpayer action be imposed under Section 112(1) ITA 1967?

6.2.1.2 Will taxpayers be automatically imposed under Section 114(1) ITA 1967?

6.2.1.3 Will To Mat be imposed under Section 119 (A) ITA 1967 because he did not keep
the record?

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6.3 The High Court’s Decision

The High Court can be affirmed with the SCIT decision to impose Tok Mat based on the
relevant section. Facts found by SCIT are very clear that breaking the law of Income Tax Act
1967 based on related sections. IRBM has a right to impose a penalty towards Tok Mat. But,
Tok Mat still can make an appeal towards the High Court’s decision.

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CONCLUSION

Tok Mat’s case is a reference to a person who wants to propose an Approved Permit (AP) car
dealers because they need to know the procedure, terms and conditions before entering this
field. Tok Mat cannot agree with Mr Lim’s request without any agreement because they want
to do a business that involves law. As per Tok Mat’s case, if he wants to involve a person in
the business, he needs to fulfil partnership agreement and there are outlines for each party. This
case will not involve other government agencies except IRBM because income that received
by Tok Mat is taxable. As a taxpayer we need to declare our income to IRBM even though the
chance of being audited is slim. This is our responsibility as a taxpayer and IRBM always gives
a platform to make a discussion regarding tax if there are any queries although taxpayers have
the same situation like Tok Mat. Moreover, it's really important for taxpayers to keep
documents related because if anything happens in the future, at least taxpayers still have
supporting documents to propose. In Tok Mat’s case, although SCIT can value his income and
expenses through the procedure, chances of Tok Mat to self-defence in the High Court are quite
tough because no supporting documents can be shown. Lastly, if we make a mistake, there is
no wrong to admit but we need to fix the mistake and find a solution.

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REFERENCE

Chuo Kuo Seng (2018). Strategizing & Managing: Critical Tax Issues 2018. Deloitte Tax
Services Sdn. Bhd

Income Tax Act 1967. Kuala Lumpur: International Law Book Services.

Mariati Norhashim, M. N. Abu Bakar (2018). AP Cars Sdn Bhd. Asian Journal of Case
Research 11(S): 6 – 10 (2018)

Network, A. N. (2013). Causes of tax evasion and their relative contribution in Malaysia: an
artificial neural network method analysis. Jurnal Ekonomi Malaysia, 47(1), 99-108.

Tax Investigation Framework (2018). Inland Revenue Board of Malaysia.

AML/CFT. (2021). Retrieved 13 December 2021, from https://amlcft.bnm.gov.my/

Lembaga Hasil Dalam Negeri. (2021). Retrieved 18 November 2021, from


https://www.hasil.gov.my/bt_goindex.php?bt_kump=5&bt_skum=5&bt_posi=3&bt
_unit=7000&bt_sequ=11

Lembaga Hasil Dalam Negeri. (2021). Retrieved 18 November 2021, from


https://www.hasil.gov.my/bt_goindex.php?bt_kump=5&bt_skum=1&bt_posi=9&bt
_unit=1&bt_sequ=2

MITI Confirms Another 36 Bumiputera Companies Made AP Holders. (2019). Retrieved 19


November 2021, from https://www.malaysiakini.com/news/467824

Suruhanjaya Pencegahan Rasuah Malaysia (SPRM). (2021). Retrieved 16 November 2021,


from
https://www.sprm.gov.my/index.php?page_id=75&articleid=445&language=en

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