Assume it is 31 January 2021. Enercall Sdn Bhd (ESB) is in the business of trading in sports equipment for three years. Currently, the company’s paid up capital is MYR2 million. Its current financial year ended on 31 December 2020. The company’s revenue and chargeable income was approximately MYR20 million and MYR500,000 respectively for each of the past three years. The company intends to expand its operation in the coming year due to escalating demand from overseas customers. It is expected that its revenue and chargeable income will grow by 30% and 20% respectively. The company requires additional capital of MYR3,000,000 for the expansion programme. The company has placed some fixed deposits (MYR200,000) in the bank. Normally, the fixed deposit interest paid by the bank amounted to 3% per annum. The following are the proposed methods of capital injection of MYR3,000,000 for the business expansion of which ESB intend to complete by 15 March 2021: Proposal 1 The company had acquired for investment purposes 400,000 ordinary shares of MYR1.00 each in Comtel Sdn Bhd (CSB), a controlled company, for a consideration of MYR500,000 on June 1, 2017. At that time, CSB owned 4 units of factory premises worth MYR15,000,000, and other tangible assets worth MYR4,000,000. ESB expects to sell all its shares in CSB for MYR8.80 per share. CSB normally declares a 4% effective dividend to its shareholders. Proposal 2 Issue 1,000,000 ordinary shares at par value of MYR1 each and the shares to be sold at MYR3.00 each. Proposal 3 Borrow MYR3,000,000 from a commercial bank with a repayment period of 5 years. Yearly interest to be borne by the company is estimated to be MYR180,000. (b) (i) For each of the proposed methods of capital injection stated above, advise ESB the relevant Malaysian tax implications on the first five years of investment. (ii) Based on the discussion in part (i) above, recommend, with proper justification, the most tax efficient proposal for capital injection for ESB. Note: Show all relevant workings whenever necessary.
