- In our previous post, we had identified 3 areas of tax which needs to be considered prior to determining the tax liability, which are "Scope of Charge", "Residence Status" and "Deductions". In this article, we will explore the concept of "Scope of Charge: Revenue and Capital Income" in detail and discuss its tax implications.
- In order for an income to be taxed in Malaysia, it needs to fall within the ambit of Section 3 of the Act, which reads:
"Subject to and in accordance to this Act, a tax to be known as income tax shall be charged for each year of assessment upon the income of any person accruing in or derived from Malaysia or received in Malaysia from outside Malaysia." - Section 2 of the Act lists down the interpretation of specific terms used throughout the Act, for example, in relation to Section 3 above:
"tax" means the tax imposed by this Act
"year of assessment", subject to subsection (5), means calendar year.
"person" includes a company, a body of persons and a corporation sole.
"Malaysia" means the territories of the Federation of Malaysia, the territorial waters of Malaysia and the sea-bed and subsoil of the territorial waters, and includes any area extending beyond the limits of the territorial waters of Malaysia, and the sea-bed and subsoil of any such area, which has been or may hereafter be designated under the laws of Malaysia as an area over which Malaysia has sovereign rights for the purposes of exploring and exploiting the natural resources, whether living or non-living. - Therefore, as long as the conditions of Section 3 are met, the income would be subject to tax. As mentioned previously, foreign source income (except for banks, insurance, sea or air transport) repatriated back to Malaysia has been exempted from income tax with effect from year 2004 by virtue of Para 28 of Schedule 6 of the Act.
- Since 'person' has been defined in the Act to include a company or body of persons, which covers clubs and associations, one cannot argue that a company or association is not a 'person' since they are not natural persons.
- As for "Malaysia" some tax payers may get creative in performing the transactions on the sea or under water and claim that the income was not performed 'in' Malaysia. Since the definition of "Malaysia" includes territorial waters, therefore, this argument is not valid.
- This brings into question income generated in international waters. Would they be subject to Malaysian tax? On principle, if the source has been derived in international waters, therefore it is tax exempt. For example, a casino on board a ship, which picks up passengers from Malaysia and only commences casino activities in international waters. The income for the 'transportation' of passenger may be taxable. However, the casino income would not be taxable in Malaysia because the activity is carried out in international waters. Of course there are other considerations pertaining to maritime revenue, which would not be discussed in this article.
- Some may even argue that income derived in the airspace, on board an airplane or helicopter, may not be subject to tax because Section 3 only mentions territories and territorial waters and no mention of air space! Although, logically airspace should be covered as part of 'territories of the Federation of Malaysia', Section 3 only mentions subsoil, sea bed and territorial waters. No mention of airspace! By applying the literal rule of interpretation, since there is no mention of airspace, should the income, where it could be clearly proven is derived from airspace, be liable for tax? To date, we are not aware of any case law which have been tested for this. But with commercial space tourism coming closer to reality in the near future, it is possible for 'consultancy' and 'advisory' services to be rendered in 'space' which is 100 km above Earth as defined by the Karman Line. In this case, where the income is derived in 'space' 100 km above Malaysian soil, would it still be taxed under the Act? It would be interesting to find out!
- Please take note that the chargeable income for sea and air transport is determined by Section 54 of the Act. The above examples are to illustrate the derivation of other income at sea and air, not in relation to the rendering of transportation service as defined in Section 54.
- From the looks of it, it seems like the Act is quite detailed in its definition and interpretation, however, despite its detailed interpretations and definitions of the specific words used throughout, the Act does not define the most important word used within it, which is INCOME.
- In order for a person to be taxed, there must be an element of income which falls within Section 3. If the 'income' is does not qualify to be taxed, then, the person will not be subject to income tax.
- So, what is income? Since there is no definition of income given in the Act, one would need to look into the ordinary meaning of income and case laws to determine what is income and more importantly, what is taxable income?
- In general, income can be classified into 2, i.e. REVENUE and CAPITAL. In Malaysia, only revenue income is subject to the Income Tax Act, 1967, whereas Capital Income is not subjected to the Act, i.e. it is tax free! (except for capital gains which are subject to the Real Properties Gains Tax Act, 1976).
- So how does one classify income into Revenue or Capital? The general rule is that if the income arose from the day to day activity of a vocation, example, trading business, consultancy business, rental income, employment income, interest income and other frequent sources of income, this is deemed to be Revenue Income. Where the income has the characteristics of a "windfall" for example an unexpected gain, or a realisation of a long term investment, lottery winnings, gambling winnings and lucky draw prizes.
- The preliminary tests to determine whether an income is Revenue or Capital are as follows:
Frequency of the transaction
Where there is frequency in receiving the said income, it is more likely to be Revenue than Capital.
Subject matter and circumstances of the transaction
Whether the income is received due to a vocation, i.e. employment or trading activity? If so, this would be revenue income. However, if the income is for example a lottery winning or in the form of a compensation for loss of employment, then such income may be deemed Capital.
Period of ownership
The period in which an item of trade was held prior to generating the income is also a consideration on determining whether an income is Revenue or Capital in nature. Usually, items held for a long period of time prior to disposal would indicate a realisation of investment, therefore Capital in nature. Whereas, where an item is purchased and traded within a short period of time, would indicate a trading nature, thus may be deemed as Revenue in nature. - Please take note that the above is not a definitive test to determine whether an Income is Capital or Revenue. In reality, the courts have applied many tests in determining whether an income is Capital or Revenue. It has been held in the case of LFY Sdn Bhd vs DGIR that whether an income is Capital or Revenue depends on the facts and circumstances of the transaction.
- Naturally, most (if not all) tax payers would prefer to classify their income as Capital rather than Revenue in order to pay minimal (if not at all) taxes. Once, they know of the 'rules' of determining 'Capital' income, they would have the tendency to see every transaction in the light of being Capital income!
- For example, a "windfall income" is a characteristic of a Capital Income. A small time home renovator whose regular renovation contracts amount to less than RM200,000 would argue the big contract worth RM3 million he or she just landed is a "windfall" as it is out of the norm. Or an employee may argue that the 12 month bonus he or she received for the first time after working with the same employer for 10 years without any bonus is a "windfall". However, even though in the eyes of the tax payer, this is a "windfall" it is still an income received within their ordinary vocation, therefore it is a Revenue income.
- The line between Capital and Revenue often gets blurred. Especially when tax payers take the route of tax planning prior to commencing a venture and in some cases, the tax payers choose to take the route of 'creative accounting' so that their income falls within the definition of Capital income.
- Therefore, when disputes with the Inland Revenue Board cannot be resolved, the courts would look at the substance of the transaction as a whole, instead of just the 'form' of the transaction. When this happens, the tax payers who engage in 'creative accounting' to avoid taxation would be exposed, since the 'substance of the transaction' would prove that the accounting transactions were created just to avoid paying taxes.
- Tax planning on the other hand involves structuring the business operations within the provisions of the Act, to minimise their tax exposure. It is perfectly legal and within the tax payer's rights to structure their business operations to that which would give them the most optimum tax exposure.
- However, even though tax planning is legal, the Inland Revenue Board tends to disagree with certain tax planning exercises due to the interpretation of law. As such, when disputes arise, it is up to the courts to decide the correct interpretation and application of the law in relation to the disputed transaction.
- So in summary, for most people, ALL income are taxable except FOREIGN SOURCE income and CAPITAL income. The Act is quite clear on what income from 'outside Malaysia' is since it has defined the meaning of "Malaysia". However, whether an income is CAPITAL or REVENUE is not defined. Therefore, one has to consider the substance of the transaction and applicable decided case laws before arriving at the conclusion that a certain income is indeed CAPITAL in nature, therefore not taxable.
- This concludes our article on CAPITAL and REVENUE income. Kindly feel free to post your queries on Capital and Revenue income in the comments section or email us at dason@dason.com.my.
At DASON & DASON, we specialise in 3 core areas as follows: (i) Taxation, (ii) Risk & Wealth Management and (iii) Business Administration & Compliance. The articles which we post here are meant to educate the general public in our field of work and core competencies. Should you have any queries pertaining to the articles or our field of work, kindly feel free to post them in the comments section or email us at dason@dason.com.my. Thank you.
Saturday, 25 January 2014
Scope of Charge: Revenue vs Capital Income
Sunday, 19 January 2014
Tax Law and Interpretation
- In this article, we will briefly discuss about the Income Tax Act, 1967 and the misconceptions about the role of the Inland Revenue Board and how the law works in Malaysia.
- The common misconception people have about the Income Tax Act, 1967 is that the law is actually set by the Inland Revenue Board (IRB) and therefore the IRB would have the final say in any tax disputes.
- In reality, the laws pertaining to Income Tax are determined by Parliament and the IRB are entrusted to enforce the law. This means that the IRB officers are also bound by the provisions of the Income Tax laws and if the tax payer is unhappy with the assessment raised, there are appeal procedures available under the law.
- Another important matter pertaining to the tax law in Malaysia is the rule of interpretation. In law, there are generally 3 rules of interpretation, namely, golden rule, mischief rule and literal rule. In short, the golden rule and mischief rule allow a certain degree of discretion in the interpretation of the wording of the law to determine the 'purpose' or 'fairness' of the application of law. However, the literal rule demands strict application of the law to the letter of the law. This means, there is no room to consider the 'purpose' or 'fairness' of the application of the law.
- In Malaysia, tax laws are are interpreted using the literal rule. This has been determined in the case of Mamor Sdn Bhd vs Director General of Inland Revenue. So, what does this mean to the tax payer? It means that if a certain provision is not literally stated in the Act, then we cannot make presumptions about it.
- Let's take a look at the provisions of Section 3 of the Act which reads as follows:
"Subject to and in accordance with this Act, a tax to be known as income tax shall be charged for each year of assessment upon the income of any person accruing in or derived from Malaysia or received from outside Malaysia." - Applying the literal rule on the above, in order for income tax to be charged, there must be an element of 'income', it must be earned by a 'person' in Malaysia or received in Malaysia from outside Malaysia.
- If for example, in a highly unlikely scenario, a show animal is able to legally receive an income of say RM1 million a year in its own name in Malaysia, it would not be subject to tax because it is not a 'person' as defined under Section 2 of the Act. The definition of a 'person' under the Act is limited to natural individuals, companies and body corporates.
- Even though, it would seem unfair that a natural person who earns RM80,000 would be subject to tax and the show animal in the above example which earns RM1 million is not taxed. One cannot argue that the animal must be taxed due to fairness under the literal rule of interpretation of the Income Tax Act, 1967. If the Golden rule or mischief rule of interpretation is used, then probably one can argue that the show animal needs to pay tax. However, since it has been decided in the Mamor case that the literal rule is to be applied, it is a binding precedent which will not be changed with regards to the interpretation of the Income Tax Act, 1967.
- The above scenario is of course absurd, however it is to illustrate the point that since the literal rule is applicable, one has to read the Act to the letter when dealing with tax matters, instead of making assumptions or drawing logical conclusions.
- Frequently we encounter clients who argue that they refuse to pay taxes because they feel it is unfair due to various reasons. Sometimes, their reasons and circumstances may even be justified given the circumstances. However, even with the best justification, one cannot be exempted from paying tax unless it is specifically allowed under the law, i.e. one cannot refuse to pay tax on the grounds of just and equity because of the literal rule of interpretation used on the Income Tax Act, 1967, which clearly states that income tax liabilities must be paid, even if the person is no longer alive!
- This concludes our article on Tax Law and Interpretation. We hope that this article would set the foundation on the significance of the wordings of the law and its application. The next article would deal with the concept of "Scope of Charge" and how to determine whether an income is taxable in Malaysia or not.
Saturday, 18 January 2014
Introduction to Malaysian Taxation
- In Malaysia, there are 2 types of tax systems in operation, which are, direct and indirect taxation. Direct taxation involves paying taxes on income or gains generated from a venture and indirect taxes is imposed by way of tariffs, custom duties, sales tax, services tax and the soon to be implemented Goods and Services Tax better known as GST.
- Direct taxes come under the purview of the Inland Revenue Board whereas indirect taxes come under the purview of the Royal Malaysian Customs Department. Ultimately, both these agencies come under the Ministry of Finance.
- The focus of these articles would be on the direct taxation system, which is legislated by the Income Tax Act, 1967 (henceforth referred to as the Act). However, we would post articles on indirect taxation and other tax related matters from time to time.
- For many, taxation is a very complicated subject, with many rules and regulations to be adhered to. But in reality, the 'complication' actually boils down to only 3 matters. Once these 3 matters are identified, computation of the income tax can be done by applying the appropriate tax rate. The 3 matters of consideration are "Scope of Charge", "Residence Status" and "Deductions".
- The "Scope of Charge" determines the chargeability of the income. Section 3 of the Act sets out 2 conditions for income to be taxed in Malaysia. First, the income must be accrued or derived, i.e. earned in Malaysia. The second condition is that the income must be received in Malaysia from outside Malaysia, i.e. foreign sourced income.
- However, with effect from year 2004, foreign sourced income which are repatriated back to Malaysia is no longer subject to tax by way of the exemption granted under Para 28, Schedule 6 of the Act. As such, the second condition mentioned above is no longer applicable for everyone except, companies in the business of banking, insurance, sea or air transport.
- The "Residence Status" would determine the applicable tax rates, whether tax reliefs are available (for individual tax) and/or whether the income derived would be subject to withholding tax and in some cases, whether income would be exempted from tax. In the context of the Act, citizenship does not determine the Tax Residence status. A person would be deemed to be a Tax Resident so long as the individual (whether citizen or not) satisfies the conditions (i.e. the number of days stay in Malaysia) as set out in Section 7 of the Act, and Section 8 for Companies.
- The "Deductions" comprise of expenses and reliefs which may be claimed against the income to reduce the taxable income. These 'deductions' come in the form of expenses, capital allowances, double deductions, and personal reliefs which are allowed under various provisions of the Act, the specifics of which, will be discussed in future articles.
- If there are only 3 matters of consideration to taxation, how can it get complicated? The complication arises due to the interpretation of the law. Naturally, the tax payer would like to interpret the law to his or her benefit and pay as little tax as possible whereas the Inland Revenue Board would take the view of maximising tax collection for the government coffers. This differing view ultimately leads to tax disputes, and where no resolution can be found between the tax payer and the authorities, the matter would need to be referred to the courts to interpret and resolve.
- This concludes our Introduction to Malaysian Taxation article. Our future articles would be a further discussion on the topics of "Scope of Charge", "Residence Status" and "Deductions". If you have any queries on this article or any other tax related questions, kindly feel free to post it on the comments or email us at dason@dason.com.my. Thank you.
Monday, 23 December 2013
Property Investment Musings
- The second half of 2013 witnessed some major changes in the areas of banking, property and taxation. Loan approval was based on net income after all deductions. In the past, it was based on gross income.
- This move alone handicapped a significant number of applicants and many had their loans rejected or approved for lower amounts instead. The buyer thus had to forego the purchase or had to come out with higher down payments.
- For those who poured out high down payments, the reduced disposable cash served its intended goal, which is to stifle speculation activity for those who aimed to flip it as soon as practicably possible.
- However, this measure did not stop foreigners who had the benefit of higher exchange rates from making continued and sustained purchases. Very often, these foreigners made cash purchases and the tweaking of loan requirements were of no consequence to them.
- Then came the next salvo. Minimum price for property purchase by foreigners was raised to RM1m and this was coupled with an upward revision of the Real Property Gains Tax (RPGT).
- By referencing against the Singapore Dollar (SGD) at an exchange rate of RM2.50, the entry price thus became SGD400k. Not exactly a deterrent since HDB flats in Singapore cost way more than that.
- As such, genuine foreign buyers still made a bee-line to developers doors albeit the need to fork out more in terms of entry price. This thus made the foreign quota allocated by developers, a sure sale.
- The RPGT put a major halt to speculators who bought just to trade it away as a commodity. Coupled with restrictive lending, a dampener has been put in place to restrict runaway prices.
- The effectiveness in the interim at least, looks promising. Only time will tell whether these cooling measures have achieved its intended outcome.
- While foreigners seem to be unscathed by these revisions, the general pulse among local purchasers look a little withered these days. Those who jumped into the property bandwagon at elevated prices seem to have no spare cash to purchase another unit.
- This is evident by the new banners put up by some developers. The artwork may have changed but the model is still the same. It simply indicates that these houses remain unsold even though the banner and buntings have faded due to rain and sunlight.
- Usually, these are luxury units such as bungalows and semi-detached houses. Locals simply do not earn high enough to afford while foreigners who have no problem with the price, have used up their quota. The developer thus, is left with unsold units.
- Locals who bought at steep prices in the past mainly did so out of fear rather than need. Many, whom we have spoken to, were willing to part with their entire savings due to the fear of not being able to afford a house in future.
- Another segment bought extra units either as investments for their children or simply out of greed to capitalise on the frenzy of fear by selling it to those who missed purchasing it in the past.
- Back to the unsold units. we anticipate the usage of very creative financing options by developers to get these units sold. Among the popular methods known is the rebate approach to reduce initial down payment to the popular guaranteed rental scheme.
- Our thoughts are that this will continue for a while and if the “discounts” are enticing enough, there will be takers. For now, prices still seem to be at lofty heights and we don’t see them crashing down.
- Otherwise, there will be pandemonium in the financial markets with banks, developers, loan borrowers and even the stock market experiencing major turbulence which can bring back memories of the 1997 financial crisis.
- As we see it, either one has to increase income to stay where one wants to live, or consider moving to areas beyond city limits where it’s more affordable. Such is the price of development.
- Otherwise, the government has to come out with significant number of units of affordable housing within city limits or drastically improve our badly needed public transport system to encourage migration to suburban areas. Only time will tell how this pans out.
- In the meantime, here’s wishing everyone all the best in finding your property of choice. May you find it sooner rather than later.
- Merry Christmas and Happy 2014!
Tuesday, 19 November 2013
Money Matters
- A call came from a client who recently acquired a house in Serene Park and was re-looking at his MRTA (Mortgage Reducing Term Assurance) options.
- From our previous dealings, we have suggested to take MLTA (Mortgage Level Term Assurance) instead, to which he is agreeable after balancing the pro’s and cons of the plan. He was also looking at a plan that covers Critical Illnesses (CI) rather than the basic coverage of Death & Disability.
- The new loan was at RM265k. Around a year ago, he acquired an apartment which carried a RM200k loan and he took up an MLTA plan to mitigate the risk.
- As our meeting went on, he informed us that the apartment has been since been sold off and was in the process of changing hands. This transaction was expected to be completed in about 3 month’s time.
- The question thus is, how much should he take for the new loan in view of the soon to be completed disposal? Should he re-cycle the previous MLTA and just top up the difference of RM65k or take a plan for the full RM265k since the previous unit has yet to be disposed in its entirety?
- If one is paranoid, then, the new MLTA should be at RM265k. However, this may be an overkill since the apartment is already on its way out. There is such thing as risk and then there is calculated risk.
- We explained to him that, when it comes to property investment, it may not be practical to insure the entire amount of loan for all properties. In practice, one should categorise properties as core holdings and trade commodities.
- The core units should be protected in full as the primary intention is for long term retention (for self use or rent collection) while the other group is held with the aim of disposal should the right situation arise.
- Examples of core units are the house one resides in, the office one operates from as well as other units that are meant for portfolio building.
- He thus concluded that the house is a core unit that must be protected from risk and the apartment as a trade item. We suggested that he performs this core/non-core asset exercise periodically to gauge his risk exposure and the mitigating action needed.
- In the end, he decided to take an additional coverage of RM100k instead. The rationale was to have an additional RM35k for the family even after the house loan has been settled in full.
- We suppose, when one is a husband/father, leaving something extra behind as a parting gift is the least one can do.
- Loans are a good financial tool but just like fire, if precautions are not there, it can burn the house down. Happy investing!
Sunday, 6 October 2013
Property Investment Musings
- Property investment can be a high stakes game and sometimes when the opportunity presents itself, a fast decision, albeit with risk attached, can be very rewarding.
- A case in hand relates to our client who had to make a snap decision when the situation arose. Many would have gone home to think or even sleep over it when big ticket items come by. We are of the opinion that to be extraordinary, one needs to act and live extraordinarily.
- It was a Sunday afternoon in August 2010 and everyone at home was in deep slumber. Unable to join in the siesta, he dropped by SP Setia’s sales office in Bukit Indah to kill time. On display was the mock-up of the then latest offering known as Indah Walk 3 Lifestyle Offices. It was a 5-storey retail and office block with around 140 units in various sizes.
- On enquiry, some units were still available especially inner ones that were not facing the main road. Since this was an office block with lifts, the general rule of getting ground/lower units may not apply. Higher may actually be better.
- However, being a commercial entity, ground floor units are the most valuable due to ease of access, but the developer was only renting them out. This automatically made the highest floor, especially the main road facing corner unit as the most valuable.
- On display was a building plan of all the units available with coloured stickers on them indicating those that have been sold and those that are still available. Naturally, he eyed the blank units and spoke to the sales staff with regards to pricing and financing matters.
- This went on for a good one hour and what was supposed to be a casual visit to the developer’s office is slowly morphing into a potential unplanned purchase. With his interest piqued, he needed a second opinion from a trustworthy party.
- He then phoned his business partner to drop by and join-in the enquiry. Upon arriving, the partner re-visited the display sheet and noticed that the top floor corner unit facing main road had a different coloured sticker from all other units that were already sold.
- When asked, it turned out to be a previously booked unit where the purchaser failed to secure a loan. The best saleable unit was now available for the picking! However, for a 2,000 sq ft office, it was priced at a steep RM426k.
- Back then, this was a relatively high number even for a commercial unit. Today, at RM213/sq ft, it’s practically a steal. Many residential condominiums are priced between RM500 – RM1,000/sqft, what more commercial lots.
- Back to our case. A decision would have to be made and it has to be made fast. Just about anyone can place a booking fee as the thinking and talking process is going on.
- Since it was just a casual visit, no money was brought for the RM3k booking fee. Going to the ATM machine risked the unit being intercepted by another lucky buyer.
- To his surprise, the partner had the exact RM3k in his pocket. It was the prior day’s takings from their mini market that has yet to be banked in. Talk about luck. Getting a cool unit and having the exact amount of booking fee!
- The transaction was done and with the loan kicking in around 3 weeks later, he was the proud owner of a nice office unit. Today, that unit is leased out to Dason & Dason and we have prominently displayed our signboards in the most elevated and advantageous position as seen from our profile picture above.
- Despite our persuasion, he is unwilling to part with the unit, citing that he was destined to be its owner with such series of occurrences. We suppose so too.
- When presented with an opportunity, a quick decision may sometimes be needed. We reckon, the Greek poet Homer was right when he wrote, “Fortune favours the Brave”. In this case, we suppose luck played a big part in being brave.
- Always be on the lookout for such deals. Opportunity knocks on everyone’s door. The question is, are we ready to welcome it in?
- Happy investing!
Monday, 16 September 2013
Money Matters
- Every now and then, our clients and friends will enquire about savings programmes that assist in reducing taxes and building a retirement nest egg.
- We dutifully show them the various options available and give them a projected value on maturity.
- Most plans tend show 2 sets of Illustration, one being the most favourable and the other, the most conservative. In all reality, both will not occur as it is improbable to have a consistent set of returns every year. There will be up’s and equally, downs.
- A mid-point would thus be the most practical value to gauge expectations. Although simplistic in approach, it is still better than relying on either extreme.
- At this point, one in two times, we get remarks like “The plan gives back RM100k in 20 years time? What is the value of RM100k then? What can it do with inflation being so high?”
- Usually, this remark comes from those who are highly educated and holding decent paying jobs. The "normal" ones usually just get things started and move on to other matters.
- In our years of practice, the ones who got things done are living reasonably comfortable lives and are midway through their retirement plans. When they retire, they will cash out their EPF/CPF as well as live off the Private Pension Plans that we have helped structure.
- They may not be wealthy, but they will have money to live, eat, go for vacation and enjoy the simpler things in life with dignity. They will not have to beg and depend on anyone else but themselves.
- The intelligent ones however, keep talking about how inflation eats away values and are constantly seeking for plans that will beat inflation. Even after 10 years, they are still talking and talking but just never getting down to doing.
- They are just too smart for their own good. They are procrastinators who just keep delaying and delaying. When they do get down to doing it, they will analyse it so much that in the end, they are back to square one.
- Back to Point 5 above. we agree that RM100k can get a bungalow 20 years ago but can only be the down payment for a cluster house today. Purchasing power has deteriorated over the years due to inflation.
- But the fact remains, RM100k is still a big sum of money back then and still is now. Just how many ordinary people can casually raise RM100k as and when needed? The sooner we take the first step towards implementing a savings plan that disciplines us, the safer we are in our greying years to come.
- The decision made by the Young You today determines’ how the Old You will be in years to come. If you have yet to start any, get it done. If you have done one, get a second one started. If you have done an Endowment, get an Annuity started. There must be progress.
- Here’s wishing you all the best in getting things moving. Just don’t let too much analysis lead to paralysis.
- To quote the immortalised slogan from Nike, “Just Do It!”.
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