# Labuan Tax: the 3% Regime, Substance Rules and When It Fails

> What the 3% Labuan rate actually covers, the employee and operating-expenditure substance tests that switch it to 24%, the deduction restriction that penalises the Malaysian payer, and the situations where a Labuan structure is the wrong answer.

- Category: taxation
- Language: en
- Status: published
- Updated: 2026-08-14
- Canonical: https://negaraku.md/en/taxation/labuan-tax-regime

---

Every Labuan brochure opens with the same number: 3%. It is accurate, and it is
the least important fact about the regime.

The 3% is a rate on a base that most promoters describe loosely, granted only if
you clear substance tests that are now enforced with worked examples naming a
tea lady, and payable by an entity whose Malaysian counterparties may be denied
a deduction on every ringgit they send it. The tax bill on a badly built Labuan
structure usually does not land on the Labuan company at all. It lands on the
Sdn Bhd that pays it.

This page covers what the statute says, what the Director General's guidelines
now require, and the situations where the honest answer is that Labuan is the
wrong tool.

## What does the 3% actually apply to?

Section 3 of the Labuan Business Activity Tax Act 1990 (LBATA) charges a Labuan
entity to tax on its **Labuan business activity**. Everything else it does falls
outside the Act and is taxed under the Income Tax Act 1967 (ITA) in the normal
way, by force of s.2(3)(a).

A Labuan business activity is either a **Labuan trading activity** or a **Labuan
non-trading activity**, carried on in, from or through Labuan, excluding
anything that is an offence under written law.

| | Labuan trading activity | Labuan non-trading activity |
| --- | --- | --- |
| Definition | Banking, insurance, trading, management, licensing, shipping operations, or any other activity that is not a non-trading activity (s.2) | Holding investments in securities, stock, shares, loans, deposits or other property situated in Labuan, on its own behalf (s.2) |
| Charge | **3%** on chargeable profits (s.4(1)) | **Not charged to tax** (s.9(1)) |
| Base | Net profits as reflected in the **audited accounts** (s.4(2)) | n/a |
| Fails substance | 24% (s.2B(1A)) | 24% (s.2B(1A)) |

Two consequences follow that are routinely missed.

**The base is audited net profit, not chargeable income.** Section 4(2) says
chargeable profits are the net profits in the audited accounts. There is no
capital allowance computation, no add-back schedule and no loss carry-forward
machinery of the kind Schedule 3 and s.44 of the ITA provide. Your accounting
policies are your tax computation.

**Mixing the two collapses into trading.** Under s.2(2), an entity carrying on
both a trading and a non-trading activity is **deemed to carry on a trading
activity**. LHDN's guideline of 10 December 2025 works this through: where an
entity runs several trading activities plus a non-trading one, each trading
activity must meet its own substance test, and the non-trading activity borrows
the substance requirement of whichever trading activity is the **core income
generating activity** — the one contributing the most income or having the most
significant economic impact.

### The intellectual property carve-out nobody mentions

Royalty income, and other income from an intellectual property right receivable
as consideration for commercially exploiting that right, is **excluded from the
Labuan regime entirely**. Sections 4(3) and 4(4) strip it out of trading
profits; s.9(2) and s.9(3) strip it out of non-trading profits; s.2B(1C) and
s.2B(1D) strip it out even of the 24% base. In every case it is taxed under the
ITA 1967.

Section 4(5) defines the right broadly: patents, utility innovations,
copyright, trade marks and service marks, industrial designs, layout-designs of
integrated circuits, secret processes, formulae, know-how, geographical
indications and plant variety protection, **whether or not registered or
registrable**.

If the plan was to park your brand or your software in Labuan and licence it
back, the plan does not work. It has not worked since the 2019 amendments.

## What are the substance requirements?

Paragraph 2B(1)(b) of the LBATA requires an adequate number of full-time
employees in Labuan and an adequate amount of annual operating expenditure in
Labuan, as prescribed by the Minister. The prescription is the **Labuan Business
Activity Tax (Requirements for Labuan Business Activity) Regulations 2021,
P.U.(A) 423/2021**, gazetted 22 November 2021 and deemed to have come into
operation on 1 January 2019 (regulation 3, on control and management, from
1 January 2021).

The First Schedule covers trading activities. A representative selection:

| Labuan trading activity | Minimum full-time employees in Labuan | Minimum annual operating expenditure in Labuan |
| --- | --- | --- |
| Labuan insurer, reinsurer, takaful or retakaful operator | 3 | RM200,000 |
| Labuan bank, investment bank, Islamic bank or Islamic investment bank | 3 | RM200,000 |
| Labuan underwriting manager, insurance manager or takaful manager | 4 | RM100,000 |
| Labuan trust company | 3 | RM120,000 |
| Labuan International Financial Exchange; self-regulatory organisation | 2 | RM120,000 |
| Labuan insurance broker, credit token, development finance, building credit, factoring company, money broker, fund manager, securities licensee, fund administrator, company management | 2 | RM100,000 |
| Labuan leasing company (not more than 10 related leasing companies) | 2 per group of companies | RM100,000 per leasing company |
| Administrative, accounting, legal, backroom processing, payroll, talent management, agency, insolvency-related or other management services | 2 | RM50,000 |

The Second Schedule covers non-trading activities:

| Labuan non-trading activity | Employees | Operating expenditure |
| --- | --- | --- |
| Investment holding other than pure equity holding | 1 | RM20,000 |
| Pure equity holding | Exempted under the Labuan Business Activity Tax (Exemption) Order 2020, P.U.(A) 177/2020 | RM20,000 |

Note the structure of the leasing entries. For 11 to 20 related leasing
companies the requirement rises to 3 employees per group, 21 to 30 gives 4, and
beyond 30 the Schedule adds one further employee per group for every additional
10 related companies — while the RM100,000 applies **per company**, not per
group. Ten Labuan leasing companies is RM1 million of Labuan operating
expenditure, not RM100,000.

One activity-specific holiday is worth flagging. The **Labuan Business Activity
Tax (Exemption) Order 2026, P.U.(A) 34/2026** (gazetted 26 January 2026) grants a
full exemption from Labuan business activity tax to a Labuan entity carrying on
qualifying **Syariah-based takaful and retakaful activities that use digital
solutions** — family and general takaful and retakaful, captive takaful for
related or associated companies, takaful underwriting managers or managers, and
takaful brokers — for **YA2025 to YA2028**. An entity carrying on both qualifying
and non-qualifying activities must keep separate accounts, each a separate and
distinct source.

### Pure equity holding is not a free pass

Most guides report the employee exemption for pure equity holding and stop
there. Two conditions survive.

The **RM20,000 annual operating expenditure in Labuan still applies**. And
regulation 3 of P.U.(A) 423/2021, which exists specifically for item 2 of the
Second Schedule, imposes control and management conditions:

- a board of directors meeting convened **in Labuan at least once a year**;
- the registered office **situated in Labuan**;
- the secretary appointed under the Labuan Companies Act 1990 **resident in
  Labuan**; and
- accounting and business records, **including board minutes, kept in Labuan**.

LHDN's guideline adds a definitional limit: pure equity holding means the entity
holds equity and derives income **solely** as dividends and capital gains. Add a
shareholder loan bearing interest and you are in item 1 of the Second Schedule,
which requires an employee.

### Fit and proper: what changed in 2025

The **Labuan Business Activity Tax (Requirements for Labuan Business Activity)
(Amendment) Regulations 2025, P.U.(A) 325/2025** replaced the words *full time
employees* with *fit and proper full time employees* throughout. LHDN issued
guidelines on **5 November 2025** setting out what that means, and they are far
more specific than anything published before.

A full-time employee counts only if all three of these hold:

1. the employee meets the fit and proper criteria;
2. the employee is employed by the Labuan entity on a permanent or contractual
   basis; and
3. the employee **performs the work physically for the Labuan entity in
   Labuan**.

Fit and proper is then broken down. The work must be **relevant to the Labuan
business activity** and must consist of office-related duties, not general
duties. The guideline gives a table. Office-related: director, manager,
secretary, administrative or accounting clerk, receptionist. General duties,
which do **not** count: despatch clerk, office cleaner, tea lady. The worked
example is blunt — a Labuan trust company with a managing director, a general
clerk and an office cleaner **fails**, because the cleaner is not a qualifying
employee.

The employee must also have qualifications, skills and experience appropriate to
the role, and must have **no conflict of interest** — no outside interests or
responsibilities that could interfere with discharging the role.

Then the provision that invalidates a large share of existing structures:

> a fit and proper full-time employee must have a **contract of service with
> that Labuan entity**, and **any method of employment through outsourcing**,
> permanent or contractual, does not count.

The example names the pattern directly: a Labuan company that engages contract
workers through an employment agency and pays their salaries through that
agency does not meet the substance requirements, because there is no contract of
service between the workers and the Labuan entity. If your Labuan trust company
supplies the bodies, the bodies are not yours.

Finally, entities in the same group may **share office premises**, but must
**segregate employees** by entity and by activity, consistently. One team cannot
count twice.

Physical presence must be evidenced — the guideline names time sheets, time
attendance systems and other appropriate methods. This is an audit standard, not
a declaration.

### The licence condition

There is a further requirement that sits above all of this, stated at paragraph
2.2 of LHDN's trading and non-trading guideline: a Labuan entity must be
incorporated and registered under the relevant Labuan legislation **and hold a
valid and effective operating licence from Labuan FSA** — for Labuan trading
activity. An expired or surrendered licence is not a licensing problem alone: it
costs the entity the 3% rate, because holding a valid and effective licence is a
condition of qualifying for the preferential treatment.

### The consequence of failing

Subsection 2B(1A) charges tax at **24% on chargeable profits** for that year of
assessment. Subsection 2B(1B) defines chargeable profits as the same net audited
profit figure. The 5 November 2025 guideline states it without qualification: an
entity that fails on the number or the criteria of employees is not entitled to
the 3% rate for trading activity or the non-chargeability for non-trading
activity, and is taxed at 24%.

The test is applied **per basis period**. There is no cure period, no
grandfathering, and no averaging across years.

## Why the deduction restriction is the real risk

Here is the part the sales material does not lead with, and the reason a Labuan
structure can cost money even when the Labuan company itself is fully compliant.

Paragraph **39(1)(r) of the Income Tax Act 1967** restricts deductions for
payments made by a **Malaysian resident** to a Labuan company, in the manner
prescribed by rules made by the Minister — the **Income Tax (Deductions Not
Allowed for Payment Made to Labuan Company by Resident) Rules 2018, P.U.(A)
375/2018**, as amended by **P.U.(A) 376/2020**.

Read that again with the parties the right way round. The Labuan company keeps
its 3%. The **Malaysian payer** loses part of its deduction. If your Sdn Bhd
pays a management fee, interest or rent to your own Labuan company, the group's
tax cost is a disallowed expense at 24% onshore, set against a 3% saving
offshore. That arithmetic frequently goes the wrong way.

The rules distinguish payment types and disallow different proportions of each,
with interest and lease rental treated more favourably than general payments.
As amended by P.U.(A) 376/2020, item 1 — interest, including any commission,
facility fee or advance fee in connection with financing — and item 2 — lease
rental — each disallow **25% of the payment**, while item 3 — all other payments
— remains at **97% disallowed**, so only 3% of a general payment is deductible.
The 2020 amendment substituted 25% for the former 33% in items 1 and 2 and left
item 3 untouched; it is deemed in force from 1 January 2019.

### The exemption, and its expiry date

Relief exists. Labuan FSA circular 269/2021 sets out the Minister's exemption
under P.U.(A) 425/2021, which exempts a Malaysian resident from paragraph
39(1)(r) for payments made:

- to a Labuan company undertaking a qualifying activity under the **Global
  Incentives for Trading (GIFT)** programme;
- to a Labuan company that has **made an election under s.3A of the LBATA**; and
- to a Labuan company **carrying on a Labuan business activity under s.2B**.

The circular then states the effective period: **from year of assessment 2019 to
year of assessment 2025**.

That window closed at the end of YA2025 — but only partly. The **Income Tax
(Labuan Company) (Exemption) Order 2026, P.U.(A) 147/2026** (made 18 March 2026,
gazetted 31 March 2026) renewed the s.39(1)(r) exemption **from YA2026 to
YA2030**, but only for payments to a Labuan company undertaking a qualifying
**Global Incentives for Trading (GIFT)** activity — a Labuan International
Commodity Trading Company licensed under s.92 of Act 704 (the Labuan Financial
Services and Securities Act 2010), trading physical commodities and related
derivatives. It does **not** renew the two broader categories P.U.(A) 425/2021
also covered — the s.3A-electing company and the general s.2B
Labuan-business-activity company. No renewing order for those was located, so for
an ordinary (non-GIFT) Labuan company the exemption lapsed after YA2025 and every
Malaysian payer making deductible payments to it is back inside the restriction.
**Verify the current position with LHDN before filing.**

Such a company carries its own substance test. Under the Labuan Business Activity
Tax (Requirements for Labuan International Commodity Trading Company) Regulations
2021, P.U.(A) 482/2021 — as amended by P.U.(A) 326/2025, which added the fit and
proper conditions — a Labuan International Commodity Trading Company must employ
at least **three fit and proper full-time employees, including at least two in
its Labuan business operational office** (per group of companies, with one more
in Labuan for every five related companies beyond five), and incur at least
**RM3,000,000 of annual operating expenditure in Malaysia, including RM100,000 in
Labuan for each company**. These figures derive from the regulations and
supersede the older Labuan FSA circular 239/2020.

One naming caution, because it causes confusion in searches: Labuan FSA titles
P.U.(A) 425/2021 the *Income Tax (Exemption) (No. 11) Order 2021*, while several
firm alerts call it the *(No. 22) Order 2021*. Cite the P.U.(A) number.

## The irrevocable election into the Income Tax Act 1967

Section 3A(1) lets a Labuan entity make an **irrevocable election** that its
profits be charged under the ITA 1967 instead of the LBATA, for the basis period
elected **and every subsequent basis period**.

Section 3A(2) sets the deadline: the election must be made in the prescribed
form and furnished to the Director General **within three months after the
beginning of the basis period** for a year of assessment, or any extended period
the Director General allows.

When is this the right move?

- The entity is loss-making or thin-margin and wants ITA machinery — capital
  allowances, loss carry-forward, group relief — instead of a flat charge on
  audited net profit.
- Substance in Labuan is genuinely unachievable, and 24% under s.2B(1A) with no
  deductions is worse than 24% under the ITA with them.
- Malaysian counterparties are the main customers and the s.39(1)(r) problem
  dominates the analysis — though the exemption that once covered electing
  companies (P.U.(A) 425/2021) lapsed after YA2025, and P.U.(A) 147/2026 now
  reaches only GIFT commodity-trading companies.
- Treaty access matters and the counterparty jurisdiction is one that will not
  extend benefits to an entity taxed under the LBATA.

The word to hold on to is **irrevocable**. There is no election out in a better
year. Model the decision across the life of the structure, not the next
twelve months.

## What a Labuan company may and may not do onshore

The commonest myth in both directions is about dealings with Malaysia. Both the
absolute prohibition and the unrestricted freedom are wrong. Section 7 of the
**Labuan Companies Act 1990** says:

- **s.7(1)** — a Labuan company may be incorporated for any lawful purpose and,
  subject to other written laws on financial services applicable to Labuan,
  **shall carry out business only in, from or through Labuan**.
- **s.7(2)** — subject to s.7(3), a Labuan company **may carry on business with
  a resident**.

### The ringgit prohibition and the notification duty are repealed

Most published guidance — and Labuan FSA's own consolidated copy of the Act — still
sets out a s.7(4) prohibition on carrying on business in ringgit, a s.7(5) duty to
notify Labuan FSA within ten working days of transacting with a resident, and a
s.7(6) list of exceptions to that notification.

**All three subsections were deleted by the Labuan Companies (Amendment) Act 2022
(Act A1653), s.4(b), deemed in force from 1 January 2019.** The related restriction
on ringgit-denominated shares in s.47(1)(a) was replaced by Act A1756 (2025) with
"expressed in any currency".

This is worth stating plainly because the error is everywhere, including on the
regulator's own website. If you are relying on a guide that describes a ten-working-day
notification duty, that guide is citing law repealed seven years ago.

What survives is **s.7(1)**: business only in, from or through Labuan. That is an
**operating-location test, not a customer test** — it constrains where the company
operates, not who it may deal with.

There is a related trap on the tax side. LHDN's guideline restricts non-trading
activity in **other property** to immovable property comprising land and
buildings **located within the boundaries of Labuan only**. The worked example
uses property in Thailand: an entity holding foreign immovable property is not
carrying on a Labuan business activity at all in respect of it, and that income
falls under the ITA 1967. The same logic reaches Kuala Lumpur property.

## Residence, treaties and the parts that are not settled

Section 3B provides that, for the purposes of double taxation arrangements under
s.132 of the ITA 1967, a Labuan entity carrying on a business is **resident in
Malaysia** if the management and control of that business is exercised in
Malaysia at any time in the basis period, and any other Labuan entity is
resident if management and control of its affairs is exercised in Malaysia by
its directors, partners, trustees or other controlling authority.

That establishes residence. It does not establish that a treaty partner will
give benefits. A number of Malaysia's treaty partners have historically limited
or excluded Labuan entities from treaty relief. Which agreements, and on what
terms, is a question to put to your adviser with the specific treaty in front of
you — we have not verified a current list and are not publishing one.

## Dormancy and filing

LHDN's guidelines on dormant Labuan entities (20 October 2022) confirm that
dormant or struck-off entities, including those in winding up or liquidation,
that derive no income **need not comply with the substance requirements**. But
an entity holding shares, real property, fixed deposits or similar investments
is **not dormant**, even if it does nothing else. The worked example refuses
dormant status to a holding company for as long as its sole subsidiary remains
unliquidated.

The permitted expenses of a dormant entity are narrow: annual return filing
under the Labuan Companies Act 1990, the secretarial fee for it, the tax filing
fee, audit fee and accounting fee. Dormant entities submit **Form LE1** with
audited or management accounts.

If an entity resumes operations mid-period, substance must be complied with from
that point — employees from the date operations commence, operating expenditure
by the end of the accounting period.

On filing, note that Labuan moved from a preceding-year to a **current-year
basis of assessment from YA2025**, announced in Budget 2024 and circulated by
Labuan FSA in November 2023. The LHDN filing programme for 2026 accordingly
requires the Labuan entity return (**e-LE1**) **within seven months from the
last day of the accounting period** that is the basis period, with a **one-month
grace period** for e-Filing. Most guides still reproduce the old rule of three
months from the commencement of the year of assessment, which came from
s.5 and s.10 of the Act as reprinted in 2021.

Tax unpaid 30 days after service of a notice of assessment is **increased by
10%** under s.13A(2).

## When Labuan is the wrong answer

Say it plainly, because almost nobody selling Labuan will.

**It is the wrong answer when your customers and suppliers are Malaysian.**
Not because of the old ringgit and notification rules — those were repealed in
2022 with retrospective effect to 2019 — but because s.7(1) still requires the
business to be carried on in, from or through Labuan, and because s.39(1)(r) sits
on the deduction your Malaysian counterparty wanted.

**It is the wrong answer for intellectual property.** Royalty and IP income is
carved out of the 3%, the 0% and even the 24% base, by four separate provisions.

**It is the wrong answer if the substance is a fiction.** Two fit and proper
employees physically in Labuan on a direct contract of service, plus RM50,000 to
RM200,000 of Labuan operating expenditure, is a real annual cost. Against a
saving of 21 percentage points, that cost only pays for itself at a meaningful
profit level — and if you cannot afford it, you do not get 3%, you get 24% on
audited profit with no deductions.

**It is the wrong answer for a small holding structure.** RM20,000 of Labuan
operating expenditure, a Labuan-resident secretary, a Labuan registered office
and an annual board meeting held in Labuan is a lot of machinery to shelter a
dividend flow that may already be exempt.

**It is the wrong answer if the driver is secrecy.** Beneficial ownership,
common reporting standard exchange and the substance regime have all moved
against that use case since 2019.

**It is the wrong answer if you are relying on repealed law.** The flat
**RM20,000 election** under the old s.7 of the LBATA — still quoted on
promotional pages — was **deleted**. The section header now reads *Election* and
the body reads *[Deleted]*. If an adviser mentions the RM20,000 option, they are
working from a pre-2019 script.

Labuan is the right answer when there is a genuine cross-border business — a
licensed activity, a captive insurer, a regional treasury, a commodity trading
operation under GIFT — that can and will be staffed and expensed in Labuan, and
whose counterparties are outside Malaysia.

## Common mistakes

- **Treating the 3% as automatic.** It is conditional on substance, per year,
  per activity, and now on each employee being fit and proper.
- **Counting the wrong people.** Cleaners, despatch clerks and outsourced agency
  staff do not count. Employees shared across group entities without consistent
  segregation do not count twice.
- **Forgetting operating expenditure for pure equity holding.** The employee
  requirement is exempted; the RM20,000 is not, and neither are the four control
  and management conditions in regulation 3.
- **Structuring IP into Labuan.** Excluded by s.4(3), s.9(2) and s.2B(1C).
- **Analysing the Labuan company in isolation.** Section 39(1)(r) taxes the
  Malaysian payer. Model both sides or you have modelled nothing.
- **Assuming the s.39(1)(r) exemption still runs.** P.U.(A) 425/2021 covered
  YA2019 to YA2025; P.U.(A) 147/2026 renews it only for GIFT commodity-trading
  companies (YA2026 to YA2030). For an ordinary Labuan company it has lapsed.
- **Making a s.3A election as a tactical move.** It binds every subsequent basis
  period, permanently.
- **Using the three-month filing rule.** Under the current-year basis the LHDN
  2026 filing programme gives seven months from the end of the accounting
  period, plus a one-month e-Filing grace.
- **Relying on a guide that still cites s.7(4), s.7(5) or s.7(6).** Those
  subsections were deleted by Act A1653 with effect from 1 January 2019. Guidance
  repeating them — including Labuan FSA’s own consolidated Act — is describing
  law that no longer exists.
- **Buying a Labuan company for Malaysian-facing e-commerce.** The s.7(1)
  operating-location test and the s.39(1)(r) deduction restriction both point the
  other way.

## What's next

If you already run a Labuan entity, the immediate work is documentary: confirm
that each employee counted toward the Schedule has a contract of service
directly with the entity, works physically in Labuan with attendance evidence,
and performs office-related work relevant to the activity. Then confirm the
operating expenditure figure is expenditure **in Labuan**, not group recharges.

If you are being sold a Labuan structure, ask the promoter three questions:
which item of the First or Second Schedule applies, what the s.39(1)(r) position
of the Malaysian payer will be for the coming year of assessment, and whether
any of the projected income is royalty or intellectual property income.

If the answers are vague, the structure is not ready — and a structure that
fails substance is taxed at 24% on audited profit with no deductions, which is
worse than the ordinary corporate position it was meant to improve on.

## Sources

- Labuan Business Activity Tax Act 1990 (Act 445), incorporating Act 833 of 2021 — https://www.labuanfsa.gov.my/clients/asset_120A5FB8-61B6-45E8-93F0-3F79F86455C8/contentms/img/documents/Legislation_and_Guidelines/Legislation/2022/Draft%20ACT%20445%20BI%20update%202021%20-%20Website%20purpose%2012%20DEC%202022.pdf (Labuan FSA)
- Labuan Business Activity Tax (Requirements for Labuan Business Activity) Regulations 2021 [P.U.(A) 423/2021] — https://www.labuanfsa.gov.my/clients/asset_120A5FB8-61B6-45E8-93F0-3F79F86455C8/contentms/img/documents/Legislation_and_Guidelines/Guidelines/tax-related/2021/Labuan%20Business%20Activity%20Tax%20(Requirements)%20Regulations%202021%20%5BP.U%20(A)%20423-2021%5D%20_25112021.pdf (Attorney General's Chambers)
- Guidelines — Labuan Trading Activity and Labuan Non-Trading Activity (LHDN.AG.600-1/10/3) — https://www.hasil.gov.my/wp-content/uploads/guidlines-labuan-trading-activity-and-labuan-non-trading-activity.pdf (LHDN)
- Guidelines — Substance Requirements for Fit and Proper Full-Time Employees of Labuan Entities (LHDN.AG.600-1/7/3) — https://www.hasil.gov.my/wp-content/uploads/20251105-guidelines-on-substance-requirements-for-fit-and-proper-full-time-employees-of-labuan-entities.pdf (LHDN)
- Labuan Companies Act 1990 (Act 441), updated version — https://www.labuanfsa.gov.my/clients/asset_120A5FB8-61B6-45E8-93F0-3F79F86455C8/contentms/img/documents/Legislation_and_Guidelines/Legislation/2022/Act%20441%20-%20Labuan%20Companies%20Act%201990%20-%20Updated%20Version_23082022.pdf (Labuan FSA)
- Circular 269/2021 — Income Tax (Exemption) Order 2021 [P.U.(A) 425/2021] — https://www.labuanfsa.gov.my/clients/asset_120A5FB8-61B6-45E8-93F0-3F79F86455C8/contentms/img/documents/Legislation_and_Guidelines/Guidelines/tax-related/2021/Circular%20PUA%20425_FINAL_29112021.pdf (Labuan FSA)
- Guidelines on Tax Treatment for Labuan Entities with Dormant Status — https://www.hasil.gov.my/wp-content/uploads/guidelines-on-tax-treatment-for-dormant-labuan-entity-20221111.pdf (LHDN)
- Program Memfail Borang Nyata Bagi Tahun 2026 — https://www.hasil.gov.my/wp-content/uploads/program-memfail-bn-bagi-tahun-2026.pdf (LHDN)
- Income Tax (Deductions Not Allowed for Payment Made to Labuan Company by Resident) Rules 2018 (Amendment) 2020 [P.U.(A) 376/2020] — https://www.labuanfsa.gov.my/regulations/legislation/act/labuan-business-activity-tax-act-1990-incorporating-latest-amendment-act-833-of-year-2021/income-tax-deductions-not-allowed-for-payment-made-to-labuan-company-by-resident-rules-2018-amendment-2020-p-u-a-3762020 (Attorney General's Chambers / Labuan FSA)
- Non-deductibility rules on payments to certain Labuan entities — https://www.ey.com/en_my/technical/tax-alerts/non-deductibility-rules-on-payments-to-certain-labuan-entities (EY Malaysia)
- Income Tax (Labuan Company) (Exemption) Order 2026 [P.U.(A) 147/2026] — https://moore.com.my/taxflash/INCOME-TAX-(LABUAN-COMPANY)-(EXEMPTION)-ORDER-2026.pdf (Attorney General's Chambers (via Moore Malaysia))
- Monthly tax developments — April 2026 — https://assets.kpmg.com/content/dam/kpmgsites/my/pdf/2026/04/monthly-tax-developments-april-2026.pdf.coredownload.inline.pdf (KPMG in Malaysia)
- Tax Exemption Order for Labuan Entities carrying on Qualifying Takaful and Retakaful Activities Gazetted [P.U.(A) 34/2026] — https://www.skrine.com/insights/alerts/february-2026/tax-exemption-order-for-labuan-entities-carrying-o (Skrine Advocates & Solicitors)
- Labuan International Commodity Trading Company — substance requirements — https://www.kensington-trust.com/resource-center/resources/labuan-international-commodity-trading-company/ (Kensington Trust Group)
- Labuan: P.U.(A) 326/2025 — LBAT (Requirements for LICT) (Amendment) Regulations 2025 — https://www.kensington-trust.com/labuan-pua326-2025-lbta-requirements-for-business-activity-amendment-regulations-2025/ (Kensington Trust Group)
- Finance (No. 2) Act 2023 [Act 851] — full text — https://www.myttx.customs.gov.my/wp-content/uploads/2024/02/WJW23%EF%80%A21341-BI.pdf (Percetakan Nasional Malaysia / Laws of Malaysia)
- Senate passes Finance Bill: Stamp Act and Labuan Business Activity Tax Act among legislation affected — https://www.allenandgledhill.com/publication/articles/26932/senate-passes-finance-bill-stamp-act-and-labuan-business-activity-tax-act-among-legislation-affected (Allen & Gledhill)

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