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Provision for Income Taxes
 6 Months Ended 12 Months Ended
Jun. 30, 2024
Dec. 31, 2023
Provision for Income Taxes [Abstract]    
PROVISION FOR INCOME TAXES

NOTE 12 — PROVISION FOR INCOME TAXES

 

Cayman Islands

 

NewGenIvf Limited was incorporated in the Cayman Islands and is not subject to tax on income or capital gains under current Cayman Islands law. In addition, upon payment of dividends by these entities to the shareholders, no Cayman Islands withholding tax will be imposed.

 

HK SAR

 

Under the two-tiered profits tax rates regime, Hong Kong tax residents are subject to Hong Kong Profits Tax in respect of profits arising in or derived from Hong Kong at 8.25% for the first HK$2 million of profits of the qualifying group entity, and profits above HK$2 million will be taxed at 16.5%. The profits of group entities not qualifying for the two-tiered profits tax rates regime will continue to be taxed at a flat rate of 16.5%.

 

Accordingly, the HK SAR profits tax is calculated at 8.25% on the first HK$2 million of the estimated assessable profits and at 16.5% on the remaining estimated assessable profits.

 

Thailand

 

The companies incorporated in Thailand are taxed on worldwide income. A company incorporated abroad is taxed on its profits arising from or in consequence of the business carried on in Thailand. The corporate income tax (CIT) rate is 20%. A foreign company not carrying on business in Thailand is subject to a final withholding tax (WHT) on certain types of assessable income (e.g. interest, dividends, royalties, rentals, and service fees) paid from or in Thailand. The rate of tax is generally 15%, except for dividends, which is 10%, while other rates may apply under the provisions of a double tax treaty (DTT).

 

Cambodia

 

The standard rate of corporate income tax (“CIT”) for companies and permanent establishments who are classified as medium and large taxpayers is 20%. For companies and permanent establishments who are classified as small taxpayers, the CIT rates are progressive rates from 0% to 20%. In view of the annual turnover of the company, the annual turnover ranges from KHR1 billion to KHR6 billion for service and commercial sectors, the company shall consider as the medium-sized company.

 

Kyrgyzstan

 

The company is subject to a corporate income tax on their aggregate annual income earned worldwide. Non-resident legal entities carrying out business activities through a permanent establishment in Kyrgyzstan are subject to profit tax on the income attributed to the activities of that permanent establishments.

 

Profit tax is calculated at a rate of 10% of aggregate annual income less allowed deductions.

 

Significant components of the provisions for income taxes for the six months ended June 30, 2024, and 2023 were as follows:

 

   June 30, 
   2024   2023 
Current tax provision Kyrgyzstan  $
—
   $83,727 
Current tax provision Cambodia   
—
    
—
 
Late penalty provision Kyrgyzstan   
—
    
—
 
Total provision for income taxes  $
—
   $83,727 

 

   June 30, 
   2024   2023 
Income/(loss) before taxes  $(387,781)  $(295,060)
Tax expenses/(credit) at the effective tax rates   (69,180)   (114,645)
Tax effect on non-taxable income   (509)   
—
 
Tax effect on non-deductible expenses   42,924    206,496 
Tax effect on utilization of tax losses   26,765    (8,124)
Income taxes  $
—
   $83,727 

 

Deferred tax asset, net

 

Significant components of deferred tax assets, net were as follows:

 

   June 30,
2024		   December 31,
2023		 
   USD   USD 
Deferred tax assets:        
– Net operating loss carry forward   28,441    28,441 
Less: valuation allowance   (28,441)   (28,441)
Deferred tax assets, net   
—
    
—
 

 

As of June 30, 2024 and December 31, 2023, the Company had net operating loss carry forward of $164,721 and $164,721. The Company believes it is less likely than not that its operations will be able to fully utilize its deferred tax assets related to the net operating loss carry forward. As a result, the Company provided 100% allowance on deferred tax assets on net operating loss.

NOTE 12 — PROVISION FOR INCOME TAXES

 

Cayman Islands

 

NewGenIvf Limited was incorporated in the Cayman Islands and is not subject to tax on income or capital gains under current Cayman Islands law. In addition, upon payment of dividends by these entities to the shareholders, no Cayman Islands withholding tax will be imposed.

 

HK SAR

 

Under the two-tiered profits tax rates regime, Hong Kong tax residents are subject to Hong Kong Profits Tax in respect of profits arising in or derived from Hong Kong at 8.25% for the first HK$2 million of profits of the qualifying group entity, and profits above HK$2 million will be taxed at 16.5%. The profits of group entities not qualifying for the two-tiered profits tax rates regime will continue to be taxed at a flat rate of 16.5%.

 

Accordingly, the HK SAR profits tax is calculated at 8.25% on the first HK$2 million of the estimated assessable profits and at 16.5% on the remaining estimated assessable profits.

 

Thailand

 

The companies incorporated in Thailand are taxed on worldwide income. A company incorporated abroad is taxed on its profits arising from or in consequence of the business carried on in Thailand. The corporate income tax (CIT) rate is 20%. A foreign company not carrying on business in Thailand is subject to a final withholding tax (WHT) on certain types of assessable income (e.g. interest, dividends, royalties, rentals, and service fees) paid from or in Thailand. The rate of tax is generally 15%, except for dividends, which is 10%, while other rates may apply under the provisions of a double tax treaty (DTT).

 

Cambodia

 

The standard rate of corporate income tax (“CIT”) for companies and permanent establishments who are classified as medium and large taxpayers is 20%. For companies and permanent establishments who are classified as small taxpayers, the CIT rates are progressive rates from 0% to 20%. In view of the annual turnover of the company, the annual turnover ranges from KHR1 billion to KHR6 billion for service and commercial sectors, the company shall consider as the medium-sized company.

 

Kyrgyzstan

 

The company is subject to a corporate income tax on their aggregate annual income earned worldwide. Non-resident legal entities carrying out business activities through a permanent establishment in Kyrgyzstan are subject to profit tax on the income attributed to the activities of that permanent establishments.

 

Profit tax is calculated at a rate of 10% of aggregate annual income less allowed deductions.

 

Significant components of the provisions for income taxes for the year ended December 31, 2023, and 2022 were as follows:

 

   December 31, 
   2023   2022 
Current tax provision Kyrgyzstan   
—
    196,116 
Current tax provision Cambodia   
—
    11,323 
Late penalty provision Kyrgyzstan   
—
    702 
Total provision for income taxes  $
—
   $208,141 

 

   December 31, 
   2023   2022   2021 
Income before taxes  $108,418   $343,988   $156,184 
Tax expenses (credit) at the effective tax rates   10,732    (124,591)   36,755 
Tax effect on non-taxable income   (39,173)   —    — 
Tax effect on non-deductible expenses   —    369,101    114,656 
Tax effect on late penalty provision   —    —    145,295 
Change in valuation allowance   28,441    —    — 
Tax effect on utilization of tax losses   —    (36,369)   (1,990)
Income taxes  $—    208,141   $294,716 

 

Deferred tax asset, net

 

Significant components of deferred tax assets, net were as follows:

 

   December 31,
2023		   December 31,
2022		 
   USD   USD 
Deferred tax assets:          
– Net operating loss carry forward   28,441    — 
Less: valuation allowance   (28,441)   — 
Deferred tax assets, net   —    — 

 

As of December 31, 2023 and 2022, the Company had net operating loss carry forward of $164,721 and $297,207. The Company believes it is less likely than not that its operations will be able to fully utilize its deferred tax assets related to the net operating loss carry forward. As a result, the Company provided 100% allowance on deferred tax assets on net operating loss.