08/09/2025

BIZ & FINANCE MONDAY | SEPT 8, 2025

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Importance of determining business commencement date

THE date of incorporation of a company is commonly misinter preted to be synonymous with the commencement of the business for income tax purposes. Once the business has been established to have commenced for income tax purposes, the business will be able to claim deduction on the expenses incurred in the production of the business income. Until the commencement date, all expenditure will not be tax deductible except for certain types of eligible capital expenditure which will be accumulated and claimed once the business has commenced. There are special pro visions in the income tax law that allow certain pre-com mencement expenditure – relating to incorporation expenses, qualifying training expenses and certain expenditures incurred overseas – to be given tax deductions. These are exceptions and the amounts allowed are relatively small. There is no specific law that dictates when a business has commenced, and it is all a question of facts which then must be determined from the existing body of case laws both locally and overseas. PETALING JAYA: Citaglobal Bhd announced that a consortium comprising subsidiary Citaglobal Renewable Energy Sdn Bhd, Abu Dhabi Future Energy Company PJSC (Masdar) and Tiza Global Sdn Bhd, received a letter of notification from the Energy Commission of Malaysia (EC) that the group has been selected as a shortlisted bidder for the development of a large-scale solar photo voltaic (LSS PV) plant with a capacity of 200MW at the Chereh Dam in Kuantan, Pahang. Upon completion, the Chereh Dam plant will be Southeast Asia’s largest floating solar power facility, surpassing the region’s current benchmark: the 145MWac Cirata Floating Solar Plant in Indonesia, developed by Masdar and PT PLN Nusantara Power. Masdar is one of the world’s fastest-growing renewable energy companies and a key enabler of the United Arab Emirates’ net-zero vision. The company is recognised for spearheading utility-scale clean energy projects globally and brings to the consortium proven expertise in developing and operating large-scale floating solar PV power plants. As at end 2024, Masdar has a total renewable energy capacity of 51 gigawatts whereby US$8 billion (RM33.8 billion) in equity was deployed in year 2024 itself. Occupying about 750 acres of water surface, the Chereh Dam plant will have a generation capacity of more than 300MWp

The general considerations Generally, any business

started with the intention of pro ducing the ultimate product. This is common in the pharmaceutical industry and the IT industry. The other ancillary factors to justify the commencement date are to ensure the business has complied with various regulatory requirements, and there is proof of registration with Employees Provident Fund, Social Security Organisation, land authorities, licence from various authorities. It is important to distinguish the activities supporting the com mencement of the business and activities that are preparatory to the commencement of the trade. This article is contributed by Thannees Tax Consulting Services Sdn Bhd managing director SM Thanneermalai (www.thannees.com).

the business. However, the initial activities are crucial, integral and part of a series of activities that must be undertaken in stages to ultimately generate the revenues. Each of these stages consti tutes business operation of a complex business. For example, in the plantation sector, you need to incur expenditure in planting, fertilising and main taining the plants before they generate the fruits in the palm oil industry, or latex in the rubber industry. This normally takes many years before revenues are generated. But the business would have com menced from the time the saplings were sowed. Similarly in complex industries which a long gestation period, com mencement would begin from the time the research and development

specific public rulings issued by the Inland Revenue Board. In the case of construction, the date the first contract is secured, or first letter of award is offered, or possession of the construction site is obtained, or the commencement of an activity which constitutes part of a series of activities that are actively carried out in the course of a construction contract business. For property developers, the commencement date would be when you purchase the property for development and start carrying out operations relating to property development (e.g. applying for per mission from the authorities). There are certain industries such as plantations, high technology or complex manufacturing which require a longer gestation period before the revenues start coming into PETALING JAYA: Agmo Holdings Bhd, a homegrown digital solutions and application development specialist, through wholly owned subsidiary Agmo Studio Sdn Bhd, has been appointed as the exclusive distributor and authorised reseller of Glem.AI in Malaysia. Glem.AI, a full-stack artificial intelligence (AI) platform developed locally by InfinitiLab Sdn Bhd, is designed to empower enterprises by automating workflows, integrating seamlessly with existing systems and deploying intelligent agents across diverse data environments. Through its multi-model, multi-modality orchestration model, Glem.AI ensures AI sovereignty by enabling deployment on-premises or on the enterprise’s preferred cloud, using their chosen AI models – whether open source or proprietary, such as DeepSeek, Qwen, OpenAI and more. As the developer and proprietor of the platform, InfinitiLab will continue to focus on advancing the technology through ongoing research, development and enhancement. Agmo Studio will co-develop the AI agents with the option to integrate their Merdeka LLM as the base model, spearhead sales, marketing, client engagement and business development initiatives, ensuring that the platform reaches businesses that

is regarded to have commenced on the day when it started its opera tions which generates income. In a normal trading business, once the people, premises and goods are available, whether physi cally or online, for sale, then the business has commenced. In manufacturing, the business would have commenced when the factory is ready to produce, raw materials are available for production and the finished goods are available for sale. In the case of a hotel, the commencement would be when the hotel is opened to the public. Certain industries such as construction and property development are guided by

Citaglobal in consortium shortlisted to develop solar project in Kuantan

Agmo to distribute InfinitiLab’s Glem.AI in Malaysia

(200MWac) and is expected to produce an average of 433 gigawatt-hours of clean electricity annually, which can power the equivalent of more than 100,000 Malaysian homes. The development is subject to certain terms and conditions, including the execution of a 21 year solar power purchase agreement between

From left: Agmo CTO Tham Chin Seng, COO Steven Low Kang Wen, Tan, Tay and InfinitiLab CTO Alvin Chua and chairman Advent Phang.

Tenaga Nasional Bhd and the consortium. The solar power plant is

enterprises while reinforcing the competitiveness of the local technology ecosystem. InfinitiLab CEO Ryan Tay Yi Wen said that by working with Agmo, they can ensure that this technology is deployed at scale and delivers measurable outcomes for organisations. At the same time, he added. Agmo’s focus on SMEs and their enterprise-driven roadmap mean that Malaysian businesses across the spectrum will have access to AI solutions built to their specific needs while ensuring enterprises realise strong return from their AI investments.

are eager to embrace digital transformation. Agmo CEO Tan Aik Keong said: “In addition to Agmo’s ongoing investments in AI innovation, the distribution of Glem.AI broadens our portfolio and accelerates time-to market by providing enterprises with a proven platform today, while we continue to build proprietary solutions that create greater long term value for their AI adoption journey.” He added the partnership between Agmo and InfinitiLab is set to strengthen the commercialisation of Malaysia-developed AI solutions, creating fresh opportunities for

scheduled to commence commercial operations by

Nov 30, 2027. Citaglobal executive chairman and president Tan Sri Dr Mohamad Norza Zakaria said this co development with Masdar en sures this project is delivered with world-class capability, while contributing meaningfully to Malaysia’s energy security and economic resilience. Masdar CEO Mohamed Jameel Al Ramahi said this win reaffirms Masdar’s expertise in floating solar and position as a trusted clean energy partner across the region and look forward to working closely with Citaglobal, Tiza Global and the government of Malaysia to help deliver on the country’s ambitious renewable energy roadmap. The development is expected to stimulate local employment opportunities in Pahang, streng then regional power reliability, and contribute to broader climate and sustainability targets set out under the National Energy Transition Roadmap.

Axis-REIT to buy industrial property in Port Klang for RM50m PETALING JAYA: Axis Real Estate Investment Trust’s (Axis-REIT) trustee RHB Trustees Bhd has entered into a sale and purchase agreement with Barry Callebaut Malaysia Sdn Bhd to acquire industrial property in Kawasan Industri Bandar Sultan Suleiman, Port Klang, for a cash consideration of RM50 million. office block annexed, a standalone double-storey office/canteen block, a single-storey detached warehouse with double-storey office block and other ancillary buildings. The property enjoys excellent connectivity via New North Klang Straits Bypass, which links to major highways including New Klang Valley Expressway, West Coast Expressway, and Federal Highway. financing ratio to 33.92% of audited total assets as at Dec31, 2024. It is targeted for completion by the first quarter of 2026. Axis REIT Managers Bhd CEO/executive director Leong Kit May said, “This acquisition highlights our strategy to acquire properties that are within prime locations served by key amenities like highways and container ports, of which Port Klang has been recognised as the 10th busiest container port in the world in a press release issued by Ministry of Transport Malaysia on Sept 1, 2025.” The property is a plot of leasehold industrial land measuring about nine acres where buildings erected on the land comprise a single-storey detached factory with double-storey The proposed acquisition will be funded with existing bank facilities, and is expected to increase Axis-REIT’s