Tax compliance is no longer limited to submitting a company’s income tax return.
With the introduction of the Malaysian Income Tax Reporting System (MITRS) under Section 82B of the Income Tax Act 1967, companies are also required to submit specified tax-related documents electronically to the Inland Revenue Board of Malaysia (HASiL).
For companies, the MITRS requirement applies from Year of Assessment (YA) 2025. This means businesses should understand the requirement and ensure that their financial and tax documents are properly prepared for submission.
What Is MITRS?
The Malaysian Income Tax Reporting System (MITRS) is an online platform used for the electronic submission of information and specified documents required by HASiL for determining a taxpayer’s taxable income and tax payable.
MITRS can be accessed through the MyTax Portal, and tax agents may also access the system through the Tax Agent e-Filing System (TAeF).
In simple terms:
Form C reports the company’s tax position, while MITRS provides HASiL with the specified documents supporting that tax position.
Who Needs to Submit Through MITRS?
The MITRS requirement was introduced progressively.
For YA 2025, implementation began with:
- Companies (File Type C)
- Limited Liability Partnerships (LLPs)
From YA 2026, the implementation has been expanded to additional taxpayer categories, including unit trusts, cooperatives, trust bodies and real estate investment trusts/property trust funds.
For companies, this means the requirement is already relevant for YA 2025 tax compliance.
What Documents Need to Be Submitted?
For companies and LLPs, the specified documents include:
1. Audited or Unaudited Financial Statements
The financial statements used as the basis for preparing the tax computation should be submitted.
For companies that qualify for audit exemption, the relevant unaudited financial statements may be submitted.
2. Income Tax Computation
The company’s income tax computation, including the relevant detailed tax adjustments, must be submitted.
This allows the tax position reported in the Form C to be supported by the corresponding tax computation.
3. Capital Allowance Schedule
Where applicable, companies must submit the complete schedule of capital allowances and relevant Schedule 3 calculations claimed for the relevant year of assessment.
4. Incentive Computation
Where tax incentives are claimed, the relevant complete computation should also be submitted.
These documents are specifically identified by HASiL under the Section 82B MITRS requirements.
When Must the Documents Be Submitted?
One of the most important points businesses should remember is that the MITRS submission is not made together with Form C.
HASiL states that the specified documents must be submitted through MITRS within 30 days after the deadline for submitting the relevant income tax return.
Therefore, businesses should not assume that submitting Form C means all tax compliance requirements for that YA have been completed.
A useful way to look at the process is:
Prepare Financial Statements
↓
Prepare Tax Computation
↓
Submit Form C
↓
Submit Specified Documents through MITRS
↓
Maintain Supporting Records
What Should Companies Prepare Before MITRS Submission?
To avoid last-minute problems, companies should prepare their documents early.
Financial Statements
Ensure that the final audited or unaudited financial statements are available in the required format.
Tax Computation
The tax computation should agree with the financial statements and the tax information reported in Form C.
Particular attention should be given to:
- Tax adjustments
- Non-deductible expenses
- Capital allowances
- Tax incentives
- Losses brought forward
- Other relevant tax adjustments
Supporting Schedules
Companies should also ensure that their capital allowance and incentive schedules are complete where applicable.
Why Is Reconciliation Important?
One of the most important steps before MITRS submission is to make sure that the information is consistent across the company’s records.
For example:
Financial Statements
↕
Tax Computation
↕
Form C
↕
MITRS Documents
If there are unexplained differences between these documents, the company should investigate them before submission.
A proper reconciliation can help identify issues such as:
- Incorrect tax adjustments
- Differences in profit figures
- Incorrect capital allowance claims
- Missing tax incentives
- Errors in the tax computation
- Incorrect information carried into Form C
What Format Should the Documents Be In?
HASiL’s MITRS guidance states that the specified documents should be uploaded in PDF format, with a maximum file size of 20 MB per document for YA 2025. Documents should be prepared in Bahasa Melayu or English; documents in other languages need to be translated into one of these languages before submission.
This means companies should also check the quality and readability of their documents before uploading them.
Can Companies Request an Extension?
This is an important point for companies to take note of.
HASiL’s MITRS FAQ states that no extension of time application is allowed for the submission of the specified documents under Section 82B.
Therefore, companies should not wait until the last few days to prepare their MITRS documents.
Once the Form C has been submitted, the company should ensure that the relevant MITRS documents are ready for submission within the prescribed period.
What Happens If a Company Fails to Submit?
Failure to comply with the Section 82B requirement is an offence.
HASiL states that failure to submit the specified documents may result in a penalty under paragraph 120(1)(d) of the Income Tax Act 1967, consisting of a fine of not less than RM200 and not more than RM20,000, imprisonment for a term not exceeding six months, or both.
This makes MITRS a compliance requirement that companies should take seriously rather than treating it as an optional administrative exercise.
Common Mistakes Companies Should Avoid
Assuming Form C Submission Is the Final Step
Submitting Form C does not automatically complete the Section 82B MITRS requirement.
Preparing the Tax Computation Too Late
The tax computation is one of the key documents required for MITRS. Delaying its preparation can affect the subsequent MITRS submission.
Financial Statements and Tax Computation Do Not Agree
Differences should be identified and resolved before the documents are submitted.
Forgetting Capital Allowance Schedules
Where capital allowances are claimed, the relevant complete schedule should be prepared for submission.
Waiting Until the Deadline
Since there is no extension of time for MITRS submission, companies should plan ahead.
A Simple MITRS Checklist for Companies
Before submitting through MITRS, businesses can use this checklist:
☑ Form C has been submitted
☑ Financial statements are finalised
☑ Tax computation is finalised
☑ Capital allowance schedule is prepared, where applicable
☑ Tax incentive computation is prepared, where applicable
☑ Financial statements agree with the tax computation
☑ Tax computation agrees with Form C
☑ Documents are in PDF format
☑ Documents are within the applicable file-size limit
☑ Documents are in Bahasa Melayu or English
☑ MITRS submission deadline has been diarised