Jason Liang

Biography

Jason Liang is a partner in the Tax, Trade and Wealth Management Practice Group at Wong & Partners. His focus is on tax disputes and controversies, with experience in handling all aspects of tax litigation. He regularly appears before the national courts and tax tribunals, representing clients on landmark tax disputes and precedent-setting cases.

He is ranked Band 3 by Chambers Asia Pacific with clients commending him as "strategic, practical and grounded in deep experience". In particular, a client highlighted that he is "very persistent in achieving results and is helpful for clients wanting to understand the pros and cons of the legal actions involved". He is also named as a Leading Partner for Tax by Legal 500 Asia Pacific. In a Legal 500 Asia Pacific interview, clients commented Jason as "warm and friendly, a good listener and able to grasp the problem at hand". Jason is further recognised as a Rising Star for Tax Controversy by International Tax Review.

He regularly speaks at various international conferences and events in Malaysia, Singapore, Hong Kong, Europe and the United States, and is often called upon to conduct trainings for various multinational clients on tax developments in emerging and growth-leading economies, transparency and information exchange on foreign tax audits and controversies, tax investigations and litigation considerations during an audit.

Practice Focus

Jason advises and represents clients on a wide spectrum of issues ranging from anti-avoidance, transfer pricing, stamp duty, real property gains tax, customs duty, indirect taxes, deductibility of capital and income expenses, and withholding tax. He has a portfolio of clients from various industries, including pharmaceutical, logistics, manufacturing and oil and gas.

Jason's practice extends to advising on legal and regulatory issues affecting multinational corporations in Malaysia. He has acted for clients in corporate exercises which includes cross border mergers and acquisitions, joint ventures and establishing of new operations in Malaysia for clients from various industries including manufacturing, telecommunications, aviation and shipping, insurance, banking and wealth management.

Representative Legal Matters

• Successfully advised and represented an American multinational semiconductor company in a stamp duty dispute with the IRB involving a MYR 8.14 million assessment on a promissory note. We assisted with filling an appeal to the High Court challenging the erroneous assessment and engaged in negotiations with the IRB, which ultimately agreed that no stamp duty was applicable and refunded the amount erroneously paid.
• Successfully represented a large American multinational company that manufactures electronics test and measurement equipment and software in an unprecedented and landmark tax appeal at the Court of Appeal involving a sale of intellectual property rights in the form of technical knowhow by the client to its related company for the sum of MYR 821.6 million.
• Successfully represented an American information technology products and services distributor in a service tax audit dispute with the IRB and Malaysian customs, securing the withdrawal of a MYR 12.17 million service tax assessment and MYR 4.87 million penalty relating to alleged imported taxable services.
• Represented Muhibbah Engineering (M) Berhad, a Malaysian public listed company in the oil & gas sector, at both the Court of Appeal and Federal Court. Being the first case of its kind, the Federal Court established a precedent on the nature of negative pledges in the client's favour, making it the law of the land.
• Represented a client's subsidiaries which are in the business of supplying aviation support services, on a landmark case and one of the first successful GST disputes in favour of the taxpayer against the Director General of Customs (DG) under the Goods and Services Tax Act 2014 at the GST Tribunal. This case set an excellent precedent in establishing a safeguard against any overreach in legal authority by the DG.
• Successfully represented a Labuan holding company in an appeal against the IRB, securing a landmark High Court decision on the application of stamp duty exemptions for share transfers involving Labuan entities.
• Successfully represented the Malaysian subsidiary of one of the world's largest offshore oil and gas well drilling companies in pursuing a judicial review application to appeal against withholding taxes.
• Successfully represented a leading Malaysian renewable energy company in a High Court appeal against an MYR 8.5 million stamp duty assessment, securing a landmark decision that novation agreements are subject only to nominal stamp duty. The matter is now at the Court of Appeal.
• Represented an American multinational manufacturer with diversified portfolios in connection to its sales tax refund claim by way of judicial review to the High Court of Malaysia. The client received a favourable decision by the High Court, making it the first case of its kind and represents a crucial Goods and Services Tax case, effectively setting a precedent that the DG is bound by the powers conferred within the four corners of the GST Act. 
• Represented our client which is one of the world's largest semi-conductor manufacturers with a dispute with the Inland Revenue Board before the Special Commission of Income Tax in relation to the extent and ambit of tax incentives.
• Advised a decentralised Web3 protocol on the Malaysian and cross border tax implications of its token issuance lifecycle and corporate restructuring, including income tax treatment, employer employee compliance, token liquidation events, and the application of badges of trade, capital versus revenue principles, and capital gains tax.

Professional Honors

• Ranked Band 3 for Tax by Chambers Asia Pacific
• Leading Partner for Tax by Legal 500 Asia Pacific
• Listed as Rising Star for Tax Controversy by International Tax Review
• Next Generation Partner for Tax by Legal 500 Asia Pacific (2023)

Professional Associations and Memberships

• Malaysian Bar
• Bar of England & Wales
• The Honourable Society of Middle Temple

Admissions

• England & Wales~United Kingdom (2011)
• Malaysia (2011)

Education

• University of Cambridge (MA Law)