The Labuan Financial Services Authority has issued a circular dated 29 April 2020 setting out the revision to the substantial activity requirements for LITC under the GIFT Programme as approved by the Ministry of Finance. The revision is effective from 1 January 2019, subject to the gazette of the amendments to the Labuan Business Activity Tax (Requirements for Labuan Business Activity) Regulations 2018 (“Regulations”).

A summary of the revision is as follows:


Labuan Entities

Minimum Number of Full Time Employees in Labuan

Minimum Amount of Annual Operating Expenditure in Labuan (RM)

Existing Regulations

Proposed Revision

Existing Regulations

Proposed Revision



·    5 or less related LITC companies


2 per group


3,000,000  per entity in Malaysia

(including minimum of RM100,000 in Labuan)



·    Every incremental of 5 related LITC companies

Increase of 1 employee for every additional 5 LITC companies

Note*: Substance is imposed on each licensed LITC.

The LOFSA’s circular as well as our earlier Tax Whiz on “Labuan Developments” and “Developments on New Labuan Tax Regime” can be accessed via the above links.

The information contained herein is of a general nature and is not intended to address the circumstances of any particular individual or entity. Although we endeavor to provide accurate and timely information, there can be no guarantee that such information is accurate as of the date it is received or that it will continue to be accurate in the future. No one should act on such information without appropriate professional advice after a thorough examination of the particular situation.

For more information on our core service offerings, please contact:

Petaling Jaya Office

Tai Lai Kok
Executive Director –
Head of Tax and Head of Corporate Tax
+ 603 7721 7020

Long Yen Ping
Executive Director –
Head of Global Mobility Services
+ 603 7721 7018

Bob Kee
Executive Director –
Head of Transfer Pricing
+ 603 7721 7029

Ng Sue Lynn
Executive Director –
Head of Indirect Tax
+ 603 7721 7271

Soh Lian Seng
Executive Director –
Head of Tax Risk Management
+ 603 7721 7019

Nicholas Crist
Executive Director –
Corporate Tax
+ 603 7721 7022

Dato’ Leanne Koh
Executive Director – 
Corporate Tax
+ 603 7721 7026

Neoh Beng Guan
Executive Director – 
Corporate Tax
+ 603 7721 7025

Ong Guan Heng
Executive Director – 
Corporate Tax
+ 603 7721 7027

Chang Mei Seen
Executive Director – 
Transfer Pricing
+ 603 7721 7028

Ivan Goh
Executive Director – 
Transfer Pricing
+ 603 7721 7012




Evelyn Lee
Executive Director –
Penang Tax
+604 238 2288 (ext. 312)

Regina Lau
Executive Director –
Kuching Tax
+6082 268 308 (ext. 2188)

Titus Tseu
Executive Director –
Kota Kinabalu Tax
+6088 363 020 (ext. 2822)

Ng Fie Lih
Executive Director –
Johor Bahru Tax
+607 266 2213 (ext. 2514)

Crystal Chuah Yoke Chin
Tax Manager –
Ipoh Tax
+605 253 1188 (ext. 320)