Jason Liang

Jason advises and represents clients on a wide spectrum of issues ranging from anti-avoidance, transfer pricing, stamp duty, real property gains tax, customs duty, indirect taxes, deductibility of capital and income expenses, and withholding tax. He has a portfolio of clients from various industries, including pharmaceutical, logistics, manufacturing and oil and gas.

Jason's practice extends to advising on legal and regulatory issues affecting multinational corporations in Malaysia. He has acted for clients in corporate exercises which includes cross border mergers and acquisitions, joint ventures and establishing of new operations in Malaysia for clients from various industries including manufacturing, telecommunications, aviation and shipping, insurance, banking and wealth management.

• Representing the Labuan Malaysian entity of an international aviation leasing company in connection with a range of tax matters including income tax, withholding tax and stamp duty issues relating to its Labuan leasing entity in Malaysia that was under heavy scrutiny by the Malaysian tax authorities, the Malaysian Inland Revenue Board (IRB).

• Assisting the world's largest international health & beauty retailer to resist the IRB's appeal in the Court of Appeal against the Special Commissioner of Income Tax and High Court's rulings in the client's favour.

• Represented Muhibbah Engineering (M) Berhad, a Malaysian public listed company in the oil & gas sector, at both the Court of Appeal and Federal Court. Being the first case of its kind, the Federal Court established a precedent on the nature of negative pledges in the client's favour, making it the law of the land.

• Represented a client's subsidiaries which are in the business of supplying aviation support services, on a landmark case and one of the first successful GST disputes in favour of the taxpayer against the Director General of Customs (DG) under the Goods and Services Tax Act 2014 at the GST Tribunal. This case set an excellent precedent in establishing a safeguard against any overreach in legal authority by the DG.

• Represented an American multinational manufacturer with diversified portfolios in connection to its sales tax refund claim by way of judicial review to the High Court of Malaysia. The client received a favourable decision by the High Court, making it the first case of its kind and represents a crucial Goods and Services Tax case, effectively setting a precedent that the DG is bound by the powers conferred within the four corners of the GST Act.

• Represented e-commerce and technology companies which have set precedents in Malaysia by pushing for a clearer definition of taxation laws on new service industries for such companies. The judicial review proceedings against the DG were in relation to a withholding tax subjected on payments made to non-resident companies to obtain various software, software development services, analytics results (i.e., data consumption patterns), and access codes to database websites.

• Represented the client in relation to three stamp duty appeals, which were filed at the High Court, against the revised notices of assessment issued by the IRB following our submission of the notices of objection against the IRB’s initial notices of assessment in respect of the three asset transfer agreements. The asset transfer agreements were entered into pursuant to a spin-off exercise led by our M&A practice.

• Successfully represented the Malaysian subsidiary of one of the world's largest offshore oil and gas well drilling companies in pursuing a judicial review application to appeal against withholding taxes.

• Advising a global manufacturer of optical products, presently subject to a transfer pricing audit by the Japan tax administration, with optimising their transfer pricing position to ensure a coherent and defensible position across both Malaysia and Japan.

• Represented our client which is one of the world's largest semi-conductor manufacturers with a dispute with the Inland Revenue Board before the Special Commission of Income Tax in relation to the extent and ambit of tax incentives.

• Malaysian Bar
• Bar of England & Wales
• The Honourable Society of Middle Temple