Stamp duty exemption on qualifying loan restructuring/ rescheduling agreements extended

The Stamp Duty (Exemption) (No. 11) Order 2021 [P.U.(A) 367/2021] (‘Exemption Order’) which exempts qualifying instruments of loan or financing agreements relating to the restructuring or rescheduling of loans or financing between borrowers or customers and financial institutions was gazetted on 15 September 2021 and is deemed to have come into operation on 1 July 2021
 
For the purposes of the Exemption Order, “restructuring or rescheduling” means any modification made to the existing repayment terms and conditions of a loan or financing agreement pursuant to a concession provided by a financial institution1 due to the inability of the borrower or customer to comply with the existing repayment schedule consequent to deteriorating financial conditions.
 
To qualify for the exemption, the following conditions must be fulfilled –
 
  1. An application must be submitted for the exemption;

  2. The instrument of loan or financing agreement relating to the restructuring or rescheduling of a loan or financing between a borrower or customer and a financial institution must be executed on or after 1 July 2021 but no later than 31 December 2021;

  3. The existing instrument of loan or financing agreement has been duly stamped under item 22 or item 27 of the First Schedule to the Stamp Act 1949;

  4. The instrument of loan or financing agreement relating to the restructuring or rescheduling of a loan of financing must not contain the element of additional value to the original amount of the loan or financing under the existing instrument of loan or financing agreement; and

  5. The application for exemption must be accompanied by the relevant document relating to the restructuring or rescheduling of the relevant loan or financing.
 
In respect of the condition set out in sub-paragraph 4, it should be noted that any increase in the loan or financing from the original amount provided under the existing instrument of loan or financing agreement will disqualify the instrument or agreement from stamp duty exemption under the Exemption Order. However, any interest or profit accrued from the restructured or rescheduled payments is not considered as an element of additional value to the original amount of the loan or financing under the existing instrument of loan or financing agreement.
 
Comments
 
The exemption from stamp duty under the Exemption Order is a continuation of measures introduced under the Stamp Duty (Exemption) (No. 2) Order 2020 [P.U.(A) 165/2020], as amended and extended by the Stamp Duty (Exemption) (No. 2) 2020 (Amendment) Order 2021 [P.U.(A) 27/2021]. This initiative will greatly assist businesses which are seeking to restructure or reschedule their existing loans or financing due to continuing financial difficulties arising from the Covid-19 pandemic.
 
However, it is to be noted that in order to qualify for stamp duty exemption under the Exemption Order, an applicant must satisfy the Stamp Office that the restructuring or rescheduling of the repayment terms and conditions under an existing instrument of loan or financing agreement is due to the applicant’s inability to comply with the existing repayment schedule in consequence of the deteriorating financial conditions.
 
Alert prepared by Lee Ai Hsian (Partner) and Tai Kean Lynn (Associate) of the Banking and Finance Practice of Skrine.
 
 

1 For the purposes of the Exemption Order, a ‘financial institution’ has the meaning assigned to “banker” under section 2 of the Stamp Act 1949. A “banker” refers to (a) any person licensed under the Financial Services Act 2013 to carry on a banking business in Malaysia; or (b) any person licensed under the Islamic Financial Services Act 2013 to carry on an Islamic banking business in Malaysia; or (c) a development financial institution prescribed under the Development Financial Institutions Act 2002.

This alert contains general information only. It does not constitute legal advice nor an expression of legal opinion and should not be relied upon as such. For further information, kindly contact skrine@skrine.com.