Iskandar Malaysia and IRDA — What Survives Now the JS-SEZ Overlays It

Almost every account of Johor’s incentive history says the same thing: the JS-SEZ superseded the old Iskandar package. It reads well and it is wrong, and the correction is exact enough to check.

The Iskandar orders were never revoked. They lapsed by their own terms. Paragraph 7 of P.U.(A) 418/2007, as amended by P.U.(A) 304/2023, stops the IDR-status exemption applying to any company commencing a qualifying activity in an approved node after 31 December 2024. MIDA began receiving JS-SEZ applications on 1 January 2025.

One scheme’s last day and the next scheme’s first day are consecutive. There was never a moment when both were open, and there is no instrument connecting them.

What Iskandar Malaysia is, legally

The Iskandar Regional Development Authority Act 2007 [Act 664] received royal assent on 12 February 2007 and came into force on 17 February 2007 by P.U.(B) 55/2007.

The region itself is not defined in the Act. Section 15(1) empowers the Minister, with the concurrence of the State Authority of Johore, to determine the area or areas by notification in the Gazette. The original determination was P.U.(B) 56/2007, published 18 February 2007 — which is listed as unavailable on the AGC portal, so the mukim-level delineation cannot be quoted.

The region grew seven months ago and almost nobody has noticed. P.U.(B) 433/2025, made by the Prime Minister on 1 December 2025 and published on 3 December 2025, determines the District of Kulai as an additional area to the Iskandar Development Region. That matters because Kulai is also JS-SEZ Flagship F (Kulai–Sedenak) — the AI, quantum, medical devices and pharmaceutical zone. The two geographies were deliberately brought into line.

Section 2(2) contains the constitutional hinge for the whole corridor model:

nothing in this Act shall be construed as reducing or limiting the jurisdiction, powers and functions of the State Authority of Johore in relation to land and local government matters

That is why IRDA coordinates rather than governs, and why a Johor project still needs state land approvals and a local authority.

IRDA is co-chaired by the Prime Minister and the Menteri Besar of Johor, with the Secretary General of the Treasury and the Director General of the Economic Planning Unit among its members.

IRDA recommends. It has never granted.

Section 5(e) of Act 664 gives IRDA the function of recommending to Government Entities incentives in relation to taxes, customs and excise duties and other fiscal incentives. The grant is the Minister of Finance’s under s.127 of the Income Tax Act 1967.

This is the same structure as NCIA under Act 687 and ECERDC under Act 688. Malaysian corridor authorities are channels and verifiers, not tax authorities — and reading them as tax authorities is what sends applicants to the wrong counter.

Section 2 does something the sibling Acts do not, though. It defines Approvals to include those related to the admission into, and departure from, Malaysia, of non-Malaysian citizens — putting immigration facilitation inside IRDA’s coordinating mandate.

The three orders, and when each window actually closed

None of the three 2007 orders has “Iskandar” in its title, which is why gazette searches for the word return nothing. All were made on 6 December 2007 and gazetted on 17 December 2007 under para 127(3)(b) of the Income Tax Act 1967.

Order	Beneficiary	Window as finally amended
P.U.(A) 417/2007 — Exemption (No. 19) para 3(1)(a)(i)	Approved developer, disposal of rights over land in an approved node	To year of assessment 2015
P.U.(A) 417/2007 para 3(1)(a)(ii)	Approved developer, rental or disposal of a building	To year of assessment 2020
P.U.(A) 417/2007 para 3(1)(b)	Development manager	To year of assessment 2024 — extended by P.U.(A) 148/2024
P.U.(A) 418/2007 — Exemption (No. 20)	IDR-status company, 10 years from commencement	Commencement by 31 December 2024 — extended by P.U.(A) 304/2023
P.U.(A) 419/2007 — Exemption (No. 21)	Non-resident withholding relief on s.4A fees, interest and royalties	To 31 December 2015 on the developer and development manager limbs
P.U.(A) 37/2024 — Exemption Order 2024	IDR-status company, 100% investment allowance over 5 years	Applications to the Minister through IRDA by 31 December 2024

Two of those extensions are worth reading directly because they show the drafting mechanism.

P.U.(A) 304/2023, gazetted 9 October 2023, amends paragraph 7 of P.U.(A) 418/2007 by substituting for the words 31 December 2020 the words 31 December 2024. It also inserts wellness and assisted living into the healthcare item and adds a seventh Schedule item, digital business and services — emerging digital technologies.

P.U.(A) 148/2024, gazetted 5 June 2024, amends subsubparagraph 3(1)(b) of P.U.(A) 417/2007 by substituting for the year of assessment 2020 the words the year of assessment 2024, and rewrites the non-application paragraph so that a development manager loses the exemption in any basis period where it has not obtained annual certification from the node project development company.

Earlier, P.U.(A) 382/2018 had already tightened the IDR-status route substantially: Malaysian incorporation, Malaysian residence, ministerial approval, an approved adequate number of full-time employees in an approved node, and adequate operating expenditure or fixed asset investment — plus a Schedule of six sectors and the exclusion of intellectual property income.

The pattern is unmistakable. Each extension bought four more years and added conditions. The 2024 round bought none — and that is the whole story of the handover.

Existing holders are not affected

This is the practical point that gets lost in “the incentives are gone”.

The orders remain on the books. Nothing was revoked. An IDR-status company that commenced its qualifying activity in an approved node on, say, 15 December 2024 still runs its ten-year exemption on its own terms — into the mid-2030s — subject to the P.U.(A) 382/2018 conditions and annual certification.

What has ended is new entry. If you hold an Iskandar incentive, the job is compliance. If you do not, the Iskandar route is closed and the live question is whether your project fits a JS-SEZ flagship activity.

Why Medini appears in no gazette

Search the federal gazette for Medini and you get nothing. That is not an indexing failure.

Both 2007 orders define the term the same way:

“approved node” means a designated area within the Iskandar Development Region as determined by IRDA

P.U.(A) 37/2024 repeats it as an area “approved by the Iskandar Regional Development Authority”.

Node designation is therefore an administrative act of IRDA, not a gazetted instrument. Medini is an approved node because IRDA determined it to be one. The incentives that “applied to Medini” are simply the orders above, applied to a company operating in a node.

The same architecture explains the node project development company — a company approved by IRDA to certify, facilitate and coordinate developer activity, whose annual certification is a condition of the exemption. A developer who fell out with its node company lost the relief, without any change in the law.

Anything else circulating about Medini’s corporate structure comes from non-official sources. medini.com.my now redirects away, and neither MIDA nor MOF publishes a Medini incentive package.

What IRDA does today

It is emphatically not wound down.

IRDA plans, facilitates and coordinates development under Comprehensive Development Plan iii (CDPiii) for 2022 to 2030, built on resilience and inclusiveness across four focus areas: a high-value economy, a productive society, a climate-resilient and carbon-neutral region, and an integrated and liveable city. Five local authorities sit inside the region — Johor Bahru, Iskandar Puteri, Pasir Gudang, Kulai and Pontian.

Its JS-SEZ role is real but shared. The Invest Malaysia Facilitation Centre Johor (IMFC-J), launched in February 2025 at Forest City, is described by MIDA as jointly led by IRDA, Invest Johor and MIDA, backed by more than thirty agencies. It runs on IRDA’s own domain and contact details, and it issues the confirmation of location within a JS-SEZ flagship zone that MIDA requires before it will process an application.

IRDA also verifies elsewhere. The four Forest City stamp duty orders of 3 October 2025 each provide that the Iskandar Regional Development Authority shall verify that the conditions are complied with — a financial-zone incentive regulated by the Securities Commission, with IRDA doing the property-side checking.

Common mistakes

Saying the JS-SEZ replaced the Iskandar incentives. No instrument does that. The Iskandar windows expired; the JS-SEZ opened the next day.

Saying the Iskandar orders were revoked. They were not. They remain in force with expired windows, which is why existing holders keep their relief.

Telling an existing IDR-status company it has lost its exemption. If it commenced by 31 December 2024, it has not.

Searching the gazette for Iskandar or Medini. Neither word appears in the titles. The orders are P.U.(A) 417, 418 and 419 of 2007.

Treating the approved developer relief as recently expired. Its land-disposal limb ended at year of assessment 2015 and its building limb at 2020. Only the development manager limb was carried to 2024.

Assuming IRDA can grant an incentive. Section 5(e) permits it to recommend.

Quoting the old five flagship zones. Western Gate and Eastern Gate no longer appear in IRDA or MIDA material; the current JS-SEZ package MIDA administers covers seven flagship zones, A to G, within the nine designated JS-SEZ flagship zones.

What’s next

If you hold an Iskandar incentive, audit the conditions rather than the rate — the 2018 and 2024 amendments made annual certification and substance requirements the live risk, and both orders now disapply themselves in any basis period where certification is missing.

If you are new to Johor, the Iskandar route is closed and the question is whether your activity maps to a JS-SEZ flagship and meets that route’s qualifying thresholds — which differ by route and are set out in the companion JS-SEZ guide. Start at IMFC-J, which is where IRDA, Invest Johor and MIDA meet, and get the flagship location confirmation before anything else.

And keep the three schemes straight. Iskandar is the region and the authority. JS-SEZ is the current MIDA package across Flagships A to G. Forest City is a financial zone under the Securities Commission. They share a map and almost nothing else.