St.Jude Medical International Holding S.A.R.L. v Lembaga Hasil Dalam Negeri (LHDN)

pa-25-55-10-2024 High Court (Mahkamah Tinggi) 6 October 2025 • PA-25-55-10/2024

Catchwords

1. This case illustrates how a single corporate transaction, seemingly routine in form, can trigger far-reaching questions concerning the reach of Malaysia’s taxing jurisdiction, the interpretation of a bilateral tax treaty (the Malaysia–Luxembourg Double Taxation Agreement), and the boundaries of public law supervision. What began as a disposal of shares in a real property company has evolved into a dispute that sits at the crossroads of domestic tax legislation and international obligations.

Practice Areas

1. This case illustrates how a single corporate transaction, seemingly routine in form, can trigger far-reaching questions concerning the reach of Malaysia’s taxing jurisdiction, the interpretation of a bilateral tax treaty (the Malaysia–Luxembourg Double Taxation Agreement), and the boundaries of public law supervision. What began as a disposal of shares in a real property company has evolved into a dispute that sits at the crossroads of domestic tax legislation and international obligations.

Judges (1)

Choong Yeow Choy Delivered

Parties (2)

Lembaga Hasil Dalam Negeri Respondent St.Jude Medical International Holding S.A.R.L Applicant

Case Significance

St.Jude Medical International Holding S.A.R.L. v Lembaga Hasil Dalam Negeri (... is a High Court (Mahkamah Tinggi) decision dated October 6, 2025 (citation: pa-25-55-10-2024). The case was decided by Choong Yeow Choy.

What was the outcome of St.Jude Medical International Holding S.A.R.L. v Lembaga Hasil Dalam Negeri (...?

St.Jude Medical International Holding S.A.R.L. v Lembaga Hasil Dalam Negeri (... is a High Court decision dated October 6, 2025. The case was heard by Choong Yeow Choy. See the full judgment for details.