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Navigating the New Incentive Framework: A Strategic Guide for Chinese Investors and Malaysian Businesses in the Manufacturing Sector

Through the Malaysian Budget 2026, the New Incentive Framework (NIF) was introduced. NIF was introduced in line with Malaysia’s National Investment Plan 2030 (NIMP) and National Investment Aspirations (NIA), with the primary objective to attract high-growth and high-value investment[1].

The development of NIF forms an important component of Malaysia’s broader strategy to sustain and diversify its investment inflows, including from foreign countries like China. Amongst others, China invested RM 28.2 billion in Malaysia, which accounted for approximately 16% of Malaysia’s foreign investment revenue.[2]

The NIF also seeks to strengthen the competitiveness of Malaysian manufacturing businesses by promoting technology-driven and value-added activities.

This article sets out the key points of the NIF and its impacts for Chinese investors and local Malaysian businesses in the manufacturing sector.

A. Introduction

Prior to the introduction of NIP, the two main tax incentives for the manufacturing sector were Pioneer Status (PS) and the Investment Tax Allowance (ITA), which were governed under the Promotion of Investments Act 1986 (PIA).

Under the NIF, PS is replaced by the Special Tax Rate (STR). In other words, the two main tax incentives currently under the NIP framework are stated as follows:

• STR; and
• ITA

Both STR and ITA for the manufacturing sector are administered under the Income Tax Act 1967[3]. It must be noted that both STR and ITA are mutually exclusive.

The company may submit an application for the said incentive starting from 1.3.2026.

Based on the statement[4] issued by the Malaysian Investment Development Authority (MIDA), the Government will no longer accept new tax incentive applications for the manufacturing sector under the PIA after 28.2.2026. However, the existing approvals shall remain valid according to the approved terms and conditions.

B. STR and ITA

The details of STR and ITA are summarised in the following table:

 

No.

Item

STR

ITA

 

1.     

Description

A reduced corporate income tax rate on the company’s taxable income.

 

Allowance on qualifying capital expenditure incurred is to be offset against statutory income.

2.     

Tax rate

0% – 15% (depending on different categories[5])

Up to 100% of allowance granted can be used to offset between 70% to 100% of statutory income.

 

3.     

Period granted [6]

Up to 15 years

 

4.     

Carried forward losses/ allowance[7]  

Accumulated losses incurred during the STR period can be carried forward for 7 consecutive years and be deducted from the company’s post-incentive income.

 

Any unutilised allowance can be carried forward to subsequent years until fully utilised.

5.     

Type of company

For any manufacturing sector

For capital-intensive local and Chinese manufacturers (particularly those bringing in machinery and production equipment)

 

The general criteria are stated as follows:

1. The company is required to hold the manufacturing licence (ML) prior to the incentive application (except for IC design and testing activities); and
2. Such ML must remain valid throughout the incentive period.

Certain subsectors carry additional requirements, such as capital investment per employee thresholds, automation adoption, sustainable practices and Malaysian workforce composition criteria and so forth.

C. NIA Scorecard

The NIF is transforming into an outcome-based initiative with a tiering approach where the application will be evaluated based on the company’s commitment and assessment using the NIA scorecard. The NIA scorecard has 6 main pillars, which are stated below:

 

No.

NIA Pillars

Objectives

Indicators in the NIA scoreboard

1.     

Increase economic complexity

a)    Development of sophisticated products & services

 

b)    High local Research & Development (R&D) and innovation intensity

 

a)    Product complexity index by Harvard Atlas

b)    Percentage share of R&D expenditure to sales revenue

c)    Level of technology

d)    Meet the Fourth Industrial Revolution (4IR) adoption of technology

 

 

 

2.     

Create high-value job opportunities

 

 

High-skilled and high-income employment

a)    Percentage share of high-skilled workers with university diploma, degree and above, or with technical certificates

b)    Median salary per worker

c)     Percentage share of workers earning RM 10,000

d)    Percentage share of Malaysian workers in the Managerial, Technical and Supervisory (MTS) level from overall MTS employment

3.     

Extend domestic linkage

 

a)    Usage of domestic input

 

b)    Deepen local supply chain integration

a)    Percentage share of local inputs

b)    Percentage share of training expenditure out of total salary

c)    Collaboration with local academia and industry

d)    Engagement in Vendor Development Programme

e)    Conduct cash pooling activities or repatriate income into Malaysia

 

4.     

Develop new and existing clusters

 

a)    Development of high-productivity sectors

 

b)    Develop new products and services locally

 

a)    Product patent

b)    Product aligned under NIA / NIMP sectors

c)    Commercialisation of R&D findings from local institutions

5.     

Improving inclusivity

 

a)    Balance economic development

b)    Human capital development

a)    Opportunity for non-employee (Internship/apprenticeship, fresh graduates with less than 3 years’ experience)

b)    Percentage share of women in top management

c)    Percentage share of workers in the vulnerable group out of the total workers

d)    Percentage share of Malaysian workers out of total workers

 

6.     

Enhance sustainability practices

Drive towards Net Zero aspirations

a)    Sustainable materials/services;

b)    Sustainable waste

c)    Sustainable management;

d)    Sustainable water consumption; and

e)    Sustainable energy consumption

 

 

 

D. Eligible Manufacturing Sectors and Excluded Sectors

The NIF applies to 15 priority manufacturing subsectors, including the following sectors:

1. Electrical and electronics;
2. Chemicals and chemical products;
3. Pharmaceuticals;
4. Medical devices;
5. Aerospace;
6. Machinery and equipment;
7. Automotive;
8. Petroleum products and petrochemicals;
9. Oleochemicals and their derivatives;
10. Food production and processing;
11. Wood;
12. Paper and furniture;
13. Textiles;
14. Apparel and footwear;
15. Strategic minerals-based products;
16. Rubber-based products; and
17. Metal

The excluded sectors stated in the Guideline dated 15.1.2026 issued by MIDA (Guideline) are stated as follows:

 

No.

Type of product(s) / activity(ies)

Sub-sectors

1.     

Mixing and blending activity

Chemical and chemical products

2.     

Fill and finish activity

 

Pharmaceuticals

3.     

Glove products and passenger vehicle tyres

 

Rubber-based products

4.     

Upstream segment, i.e. Mining and quarry

Strategic mineral-based products

5.     

All types of papers

 

(which is not applicable for security paper and company is not allowed to import waste raw material)

 

Paper

6.     

All petroleum products

 

The exclusion for petroleum products is not applicable for:

 

·      Production of petroleum products located at the Refinery and Petrochemical

·      Integrated projects which also involve the production of petrochemical products

 

Petroleum products

7.     

Liquor and alcoholic beverages

Food production and processing

 

8.     

e-Cigarette & vape products

 

Electronic and electronic

9.     

Weapons and ammunition

 

Metal

 

However, sector eligibility alone does not determine outcome. The relevant projects must satisfy pre-qualifiers and demonstrate strength across scorecard pillars.

E. Commentary

Notably, NIF represents a fundamental shift from a product-centric model to an outcome-based model. Under the previous framework, incentive eligibility was largely determined by the nature of the product manufactured or the industry sector in which the company operated, i.e. whether the product falls within the promoted list.

NIF goes beyond the conventional tax reductions, reflecting a broader policy objective of aligning investment activities with Malaysia’s national economic transformation agenda. For companies with a longer-term outlook, such alignment may offer both tax-efficiency considerations and strategic positioning advantages within the evolving industrial landscape.

Given the outcome-based nature of NIF, companies are urged to carefully assess the approach to incentive applications in Malaysia, particularly:

1. To confirm that their intended manufacturing activity falls within one of the 15 eligible subsectors and does not engage any of the excluded categories;

2. The NIA scorecard must be taken into account at the preliminary stage, as scoring performance across the 6 pillars;

3. Local incorporation and capital expenditure commitments should not be made until sector eligibility and scorecard readiness have been assessed. Proceeding prematurely carries real financial and legal risk if approval is not subsequently obtained; and

4. To proactively plan for technology adoption, workforce upskilling, and local sourcing commitments where applicable.

Importantly, obtaining approval under the NIF is not the end of the incentive journey, as ongoing compliance throughout the incentive period is critical to preserving the approved incentives.

Both Chinese investors and local Malaysian businesses stand to derive the most comprehensive and enduring benefit from the NIF by approaching it strategically from the pre-application, application, and post-approval stages. Given that the NIF for the services sector is expected to be implemented in the near future, companies with operations spanning both manufacturing and services should monitor developments closely.

 

[1] https://www.mida.gov.my/wp-content/uploads/2026/01/Guideline-Tax-Incentive-NIF_Manufacturing-Only.pdf

[2] https://www.mida.gov.my/media-release/malaysia-records-historic-high-rm378-5-billion-in-investments-with-14-9-y-o-y-growth-generating-more-than-207000-jobs-in-2024/

[3] Section 65B of the Income Tax Act 1967

[4] https://www.mida.gov.my/wp-content/uploads/2026/01/Guideline-Tax-Incentive-NIF_Manufacturing-Only.pdf & https://www.miti.gov.my/NIF

[5] Section 6(1A), Section 6(1A) and Section 65B of the Income Tax Act 1967; the special tax rate varies with different categories from new investment, less developed areas and small companies

[6] https://www.mida.gov.my/wp-content/uploads/2026/01/Guideline-Tax-Incentive-NIF_Manufacturing-Only.pdf

[7] https://www.mida.gov.my/wp-content/uploads/2026/01/Guideline-Tax-Incentive-NIF_Manufacturing-Only.pdf


About the authors

Yap Wen Hui
Senior Associate
Corporate & Investor Services
Halim Hong & Quek
wh.yap@hhq.com.my


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