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Income Tax
12 Months Ended
Dec. 31, 2019
Major Components Of Tax Expense Income [Abstract]  
Income Tax

 

8.

INCOME TAX

Under current Bermuda law, the Company is not subject to tax on income or capital gains, nor is withholding tax of Bermuda imposed upon payments of dividends by the Company to its shareholders.

The Company’s investments in the Operating Subsidiaries are held through subsidiaries incorporated in the British Virgin Islands (“BVI”). Under current BVI law, dividends from the BVI subsidiaries’ investments are not subject to income taxes and no withholding tax is imposed on payments of dividends by the BVI subsidiaries to the Company.

The Operating Subsidiaries and equity investees are governed by the income tax laws of Singapore, Thailand, Australia and the PRC.  The corporate income tax rate in Singapore was 17% for each of the three years ended December 31, 2019, and there is no withholding tax on dividends applicable to the Company.  For Thailand, the statutory corporate income tax rate was 20% for each of the three years ended December 31, 2019 and a withholding tax of 10% is levied on dividends received by the Company. Charoong Thai is listed on Stock Exchange of Thailand (“SET”). In Australia, the corporate income tax rate was 30% for 2016/2017, 2017/2018 and 2018/2019 tax years. The applicable corporate income tax rate for the subsidiaries in the PRC was 25% for each of the three years ended December 31, 2019.

Dividends received from the Operating Subsidiaries and equity investees may be subjected to withholding taxes. Under the current Singapore corporate tax system, dividends paid by a Singapore resident company is tax exempt, and is not subject to withholding taxes. In Australia, dividends paid to non-residents are exempt from dividend withholding taxes except when dividends are paid out of profit that is not taxed by Australian income tax (i.e. unfranked dividends). For Thailand, dividends paid by a company to any individual or corporate payee overseas are subject to a withholding tax of 10%. Under the Corporate Income Tax Law of the PRC, dividend distribution of profits to foreign investor(s) is subject to withholding tax of 10%.

 

 

 

8.

INCOME TAX (continued)

The major components of income tax expenses for the years ended December 31, 2019, 2018 and 2017 are:

  

 

 

2019

 

 

2018

 

 

2017

 

 

 

US$’000

 

 

US$’000

 

 

US$’000

 

Consolidated income statements

 

 

 

 

 

 

 

 

 

 

 

 

Current income tax:

 

 

 

 

 

 

 

 

 

 

 

 

Current income tax charge

 

 

1,699

 

 

 

4,068

 

 

 

4,785

 

Previously unrecognized tax loss used to reduce current income tax

 

 

 

 

 

(128

)

 

 

(1,066

)

Adjustments for current income tax of prior years

 

 

(16

)

 

 

1

 

 

 

348

 

Total current income tax

 

 

1,683

 

 

 

3,941

 

 

 

4,067

 

Deferred tax expenses/(benefits):

 

 

 

 

 

 

 

 

 

 

 

 

Relating to origination and reversal of temporary differences

 

 

374

 

 

 

243

 

 

 

1,210

 

Relating to change in tax rate

 

 

 

 

 

 

 

 

 

Previously unrecognized tax loss used to reduce deferred tax expenses

 

 

 

 

 

(298

)

 

 

(137

)

Total deferred tax expenses/(benefits)

 

 

374

 

 

 

(55

)

 

 

1,073

 

Income tax expense reported in the income statement

 

 

2,057

 

 

 

3,886

 

 

 

5,140

 

 

 

 

 

 

 

 

 

 

 

 

 

 

Consolidated statements of comprehensive income

 

 

 

 

 

 

 

 

 

 

 

 

Deferred tax related to items recognized in other comprehensive income during the year:

 

 

 

 

 

 

 

 

 

 

 

 

Change in the fair value of equity instrument measured at fair value through other comprehensive income

 

 

 

 

 

 

 

 

 

 

 

 

Recognized during the year

 

 

334

 

 

 

(84

)

 

 

(16

)

Effect of change in tax rate

 

 

 

 

 

 

 

 

 

Net loss on actuarial gains and losses

 

 

 

 

 

 

 

 

 

 

 

 

Recognized during the year

 

 

(345

)

 

 

(82

)

 

 

(154

)

Effect of change in tax rate

 

 

 

 

 

 

 

 

 

Income tax benefits charged to other comprehensive (loss) income

 

 

(11

)

 

 

(166

)

 

 

(170

)

 

8.

INCOME TAX (continued)

The parent company’s tax is filed in Bermuda, which does not have a statutory tax rate. The provision for income taxes differs based on the tax incurred by the Operating Subsidiaries, in their respective jurisdiction. The Company determines its statutory tax rate based on its major commercial domicile that is its subsidiaries in Thailand. The reconciliation of the statutory tax rate and the Company’s effective tax rate is as follows:

 

 

     

 

 

2019

 

 

2018

 

 

2017

 

 

 

US$’000

 

 

US$’000

 

 

US$’000

 

Profit before tax

 

 

1,106

 

 

 

11,332

 

 

 

18,668

 

Tax at statutory rate of 20% (2018: 20%; 2017: 20%)

 

 

221

 

 

 

2,266

 

 

 

3,734

 

Foreign income taxed at different rate

 

 

499

 

 

 

697

 

 

 

1,151

 

Expenses not deductible for tax purpose

 

 

221

 

 

 

(33

)

 

 

600

 

Utilization of previously unrecognized tax losses

 

 

 

 

 

(128

)

 

 

(1,066

)

Tax benefit arising from previously unrecognized tax losses

 

 

 

 

 

(298

)

 

 

(137

)

Net deferred tax asset not recognized

 

 

949

 

 

 

679

 

 

 

78

 

Written-off deferred tax

 

 

218

 

 

 

(4

)

 

 

10

 

Tax exempt on income

 

 

(144

)

 

 

(135

)

 

 

(245

)

Uncertain tax position

 

 

(454

)

 

 

11

 

 

 

(270

)

Return to provision adjustment

 

 

(16

)

 

 

1

 

 

 

348

 

Deferred tax liability arising from undistributed earnings

 

 

215

 

 

 

578

 

 

 

602

 

Withholding tax on dividends

 

 

355

 

 

 

270

 

 

 

349

 

Others

 

 

(7

)

 

 

(18

)

 

 

(14

)

Income tax expense reported in income statement

 

 

2,057

 

 

 

3,886

 

 

 

5,140

 

 

8.

INCOME TAX (continued)

Deferred tax

Deferred tax relates to the following:

 

 

 

Consolidated balance sheet

 

 

Consolidated income statement

 

 

 

As of December 31,

 

 

For the year ended Decembers 31,

 

 

 

2019

 

 

2018

 

 

2019

 

 

2018

 

 

2017

 

 

 

US$’000

 

 

US$’000

 

 

US$’000

 

 

US$’000

 

 

US$’000

 

Outside basis differences

 

 

(3,829

)

 

 

(3,614

)

 

 

215

 

 

 

578

 

 

 

602

 

Revaluations of financial assets at fair value through other comprehensive income (2017: Revaluations of available-for-sale investment to fair value)

 

 

(679

)

 

 

(345

)

 

 

 

 

 

 

 

 

 

Accrued interest income

 

 

(181

)

 

 

(154

)

 

 

13

 

 

 

12

 

 

 

11

 

Unutilized building allowance (net)

 

 

(36

)

 

 

(133

)

 

 

(98

)

 

 

(95

)

 

 

11

 

Unused tax losses

 

 

546

 

 

 

644

 

 

 

119

 

 

 

(459

)

 

 

455

 

Allowance for doubtful accounts

 

 

245

 

 

 

290

 

 

 

47

 

 

 

(97

)

 

 

(25

)

Inventory impairment

 

 

554

 

 

 

657

 

 

 

147

 

 

 

(236

)

 

 

(161

)

Rebates and other accrued liabilities

 

 

472

 

 

 

426

 

 

 

(46

)

 

 

(38

)

 

 

(6

)

Unpaid retirement benefits

 

 

1,553

 

 

 

1,353

 

 

 

(81

)

 

 

(54

)

 

 

(62

)

Deferred revenue and cost of sales

 

 

23

 

 

 

16

 

 

 

(6

)

 

 

(14

)

 

 

393

 

Actuarial loss

 

 

796

 

 

 

450

 

 

 

 

 

 

 

 

 

 

Unabsorbed depreciation

 

 

637

 

 

 

701

 

 

 

57

 

 

 

(55

)

 

 

(45

)

Mark-to-Market value of forward contract

 

 

 

 

 

28

 

 

 

28

 

 

 

(28

)

 

 

 

Others

 

 

(301

)

 

 

(325

)

 

 

(21

)

 

 

431

 

 

 

(100

)

Deferred tax expenses / (benefits)

 

 

 

 

 

 

 

 

 

 

374

 

 

 

(55

)

 

 

1,073

 

Net deferred tax assets

 

 

(200

)

 

 

(6

)

 

 

 

 

 

 

 

 

 

 

 

 

Reconciliation of deferred tax assets, net

 

 

2019

 

 

2018

 

 

2017

 

 

 

US$’000

 

 

US$’000

 

 

US$’000

 

Opening balance as of January 1

 

 

(6

)

 

 

(132

)

 

 

526

 

Tax benefit/(expenses) during the period recognized in profit or loss

 

 

(374

)

 

 

55

 

 

 

(1,073

)

Tax benefit/(expenses) during the period recognized in other comprehensive income

 

 

11

 

 

 

166

 

 

 

170

 

Exchange difference on translation foreign operations

 

 

169

 

 

 

(95

)

 

 

245

 

Closing balance as of December 31

 

 

(200

)

 

 

(6

)

 

 

(132

)

 

The Company offset tax assets and liabilities if and only if it has legally enforceable right to set off current tax assets and current tax liabilities and the deferred tax assets and deferred tax liabilities related to income taxes levied by the same tax authority.

8.

INCOME TAX (continued)

The Company has available unused net operating losses which arose in Thailand, China, Hong Kong, Singapore and Australia as of December 31, 2019 and 2018, that may be applied against future taxable income and that expire as follows respectively:

 

 

 

As of December 31,

 

Year of expiration

 

2019

 

 

2018

 

 

 

US$’000

 

 

US$’000

 

2019

 

 

 

 

 

784

 

2020

 

 

3,067

 

 

 

3,020

 

2021

 

 

5,246

 

 

 

5,121

 

2022

 

 

2,216

 

 

 

2,105

 

2023

 

 

4,855

 

 

 

4,760

 

2024

 

 

3,605

 

 

 

 

No expiration

 

 

1,591

 

 

 

972

 

 

 

 

20,580

 

 

 

16,762

 

Deferred tax assets have not been recognized in respect of these losses as they may not be used to offset taxable profits elsewhere in the Company, as they have arisen in subsidiaries that have been loss-making for some time, and there are no other tax planning opportunities or other evidence of recoverability in the near future. The Company did not recognize deferred tax assets of $4,038 (2018: $3,084; 2017: $2,803) in respect of tax losses amounting to $18,422 (2018: $13,698; 2017: $12,769 ).

 

In addition, the Company did not recognize deferred assets of $1,030 (2018: $792 ; 2017: $1,144) in relation to deductible temporary differences amounting to $4,695 (2018: $3,557; 2017: $4,930).

There are no income tax consequences attached to the payment of dividends in either 2019 or 2018 by the Company to its shareholders.

As of December 31, 2019 and 2018, the Company is subject to taxation in PRC, Australia, Thailand, and Singapore.  The Company’s tax years from 2011 and forward are still subject to examination by the tax authorities in various tax jurisdictions.

 

A reconciliation of the beginning and ending amounts of uncertain tax position is as follows:

 

Change in Uncertain Tax Positions

 

2019

 

 

2018

 

 

2017

 

 

 

US$’000

 

 

US$’000

 

 

US$’000

 

Balance as of January 1

 

 

674

 

 

 

706

 

 

 

828

 

Additions based on tax positions related to the current year

 

 

 

 

 

 

 

 

 

Decrease due to lapses in statute of limitations

 

 

(215

)

 

 

 

 

 

(175

)

Exchange difference

 

 

(8

)

 

 

(32

)

 

 

53

 

Balance as of December 31

 

 

451

 

 

 

674

 

 

 

706

 

 

The Company is not expecting there would be any reasonably possible change in the total amounts of uncertain tax position within twelve months of the reporting date. As of December 31, 2019, 2018, and 2017 the amount of uncertain tax position (excluding interest and penalties) included in the consolidated balance sheets that would, if recognized, affect the effective tax rate is $451, $674 and $706, respectively.

8.

INCOME TAX (continued)

The Company recognized interest expense and penalties related to income tax matters as a component of income tax expense. The amount of related interest and penalties the Company has provided as of the dates listed below were:

 

 

 

As of December 31,

 

 

 

2019

 

 

2018

 

 

2017

 

 

 

US$’000

 

 

US$’000

 

 

US$’000

 

Accrued interest on uncertain tax position

 

 

713

 

 

 

867

 

 

 

800

 

Accrued penalties on uncertain tax position

 

 

384

 

 

 

461

 

 

 

486

 

Total accrued interest and penalties on uncertain tax position

 

 

1,097

 

 

 

1,328

 

 

 

1,286

 

For the years ended December 31, 2019, 2018 and 2017, the Company recognized $81, $108 and $114 in interest and $nil, $nil and $nil in penalty, respectively. For the years ended December 31, 2019, 2018 and 2017, the Company reversed $223, $nil and $276 in interest and $71, $nil and $87 in penalties, respectively, due to lapses in statute of limitations. For the years ended December 31, 2019, 2018 and 2017, the exchange difference $(12), $(41) and $ 65 relating to interests, $(6), $(25) and $38 relating to penalty were included in income tax expenses.

The Company considers each uncertain tax positions individually, by first consider whether each position taken in the tax return is probable of being sustained on examination by the taxing authority. It should recognize a liability for each item that is not probable of being sustained. The liability then is measured using a single best estimate of the most likely outcome. The uncertain tax positions presented in the current tax liability is the total liability for uncertain tax positions.