v3.25.2
INCOME TAXES EXPENSES
6 Months Ended
Jun. 30, 2025
Income Tax Disclosure [Abstract]  
INCOME TAXES EXPENSES

17. INCOME TAXES EXPENSES

 

The United States and foreign components of income (loss) before income taxes were comprised of the following:

 

   2025   2024   2025   2024 
   For the three months ended
June 30,
   For the six months ended
June 30,
 
   2025   2024   2025   2024 
                 
Tax jurisdictions from:                    
Local – United States  $(464,759)  $(300,452)  $(939,004)  $(828,077)
Foreign – Malaysia   (165,505)   (114,614)   (401,983)   (291,139)
Foreign – China   (81)   -    (205)   - 
Foreign – Hong Kong   7,099    (7,409)   5,027    484 
Loss before income tax  $(623,246)  $(422,475)  $(1,336,165)  $(1,118,732)

 

Income tax expense consisted of the following:

 

   2025   2024   2025   2024 
   For the three months ended
June 30,
   For the six months ended
June 30,
 
   2025   2024   2025   2024 
                 
Current:                    
- Local  $-   $-   $-   $- 
- Foreign   -    (9,840)   -    (16,678)
                     
Deferred:                    
- Local   -    -    -    - 
- Foreign   -    -    -    - 
Income tax expense  $-   $(9,840)  $-   $(16,678)

  

The effective tax rate in the periods presented is the result of the mix of income earned in various tax jurisdictions that apply a broad range of income tax rates. The Company and its subsidiaries that operate in various countries: United States, Malaysia (including Labuan), Hong Kong and China that are subject to taxes in the jurisdictions in which they operate, as follows:

 

 

AGAPE ATP CORPORATION

NOTES TO CONDENSED CONSOLIDATED FINANCIAL STATEMENTS

(UNAUDITED)

(Currency expressed in United States Dollars (“US$”), except for number of shares)

 

17. INCOME TAXES EXPENSES (Continued)

 

United States of America

 

Agape ATP Corporation was incorporated in the State of Nevada and is subject to the tax laws of the United States of America with a corporate tax rate of 21% on its taxable income. Agape ATP Corporation also subject to controlled foreign corporations Subpart F income (“Subpart F”) tax, which is a tax primarily on passive income from controlled foreign corporations with a tax rate of 21%. In addition, the Tax Cuts and Jobs Act imposed a global intangible low-taxed income (“GILTI”) tax, which is a tax on certain off-shore earnings at an effective rate of 10.5% for tax years (50% deduction of the current enacted tax rate of 21%) with a partial offset for 80% foreign tax credits. If the foreign tax rate is 13.125% or higher, there will be no U.S. corporate tax after the 80% foreign tax credits are applied.

 

For the three and six months ended June 30, 2025 and 2024, the Company’s foreign subsidiaries did not generate any income that are subject to Subpart F tax and GILTI tax.

 

As of June 30, 2025 and December 31, 2024, the operations in the United States of America incurred approximately $4,738,000 and $3,799,000, respectively, of cumulative net operating losses (“NOL”) which can be carried forward to offset future taxable income or Subpart F and GILTI taxes. These balances can be carried forward indefinitely. The deferred tax valuation allowance as of June 30, 2025 and December 31, 2024 were approximately $995,000 and $798,000, respectively.

 

Malaysia

 

Agape ATP Corporation, Agape Superior Living Sdn Bhd, Agape S.E.A Sdn Bhd., Cedar ATPC Sdn Bhd., DSY Wellness International Sdn. Bhd. ATPC Green Energy Sdn Bhd and OIE ATPC Exim (M) Sdn Bhd. are governed by the income taxes laws of Malaysia and the income taxes provision in respect of operations in Malaysia is calculated at the applicable tax rates on the taxable income for the periods based on existing legislation, interpretations and practices in respect thereof. Under the Income Tax Act of Malaysia, enterprises that incorporated in Malaysia are usually subject to a unified 24% enterprise income taxes rate while preferential tax rates, tax holidays and even tax exemption may be granted on case-by-case basis. The tax rate for small and medium sized companies (generally companies incorporated in Malaysia with paid-in capital of RM 2,500,000 or less) is 15% for the first RM 150,000 (or approximately $37,500), 17% for the subsequent RM 150,000 to RM 600,000 (or approximately $37,500 to $150,000) and 24% for the remaining balance for three months ended June 30, 2025 and 2024.

 

As of June 30, 2025 and December 31, 2024, the operations in Malaysia incurred approximately $3,866,000 and $3,369,000, respectively, of cumulative net operating losses (“NOL”) which can be carried forward to offset future taxable income. Approximately $791,000, $885,000, $1,337,000, $577,000 and $277,000 of the net operating loss carry forwards will expire in 2031, 2032, 2033, 2034 and 2035, respectively, if unutilized. The deferred tax valuation allowance as of June 30, 2025 and December 31, 2024 were approximately $940,000 and $827,000, respectively.

 

Hong Kong

 

Agape ATP International Holding (HK) Limited is subject to Hong Kong Profits Tax, which is charged at the statutory income rate of 16.5% on its assessable income derived from Hong Kong. Business income derived or business expenses incurred outside the Special Administrative Region is not subject to Hong Kong Profits Tax or deduction.

 

China

 

ATPC Technology Private Limited is subject to the Corporate Income Tax governed by the Income Tax Law of the People’s Republic of China with a unified statutory income tax rate of 25%.

 

 

AGAPE ATP CORPORATION

NOTES TO CONDENSED CONSOLIDATED FINANCIAL STATEMENTS

(UNAUDITED)

(Currency expressed in United States Dollars (“US$”), except for number of shares)

 

17. INCOME TAXES EXPENSES (Continued)

 

The following table sets forth the significant components of the aggregate deferred tax assets of the Company:

 

  

June 30,

2025

  

December 31,

2024

 
   As of 
  

June 30,

2025

  

December 31,

2024

 
Deferred tax assets:          
Net operating loss carry forwards in U.S.  $994,950   $797,759 
Net operating loss carry forwards in Malaysia   938,996    824,143 
Unabsorbed capital allowance carry forward in Malaysia   1,306    3,245 
Less: valuation allowance   (1,935,252)   (1,625,147)
Deferred tax assets, net  $-   $- 

 

Uncertain tax positions

 

The Company evaluates each uncertain tax position (including the potential application of interest and penalties) based on the technical merits, and measure the unrecognized benefits associated with the tax positions. As of June 30, 2025 and December 31, 2024, the Company did not have any significant unrecognized uncertain tax positions. The Company did not incur any interest and penalties tax for the three and six months ended June 30, 2025 and 2024.