$5.$ Public Ruling $1/2023$ offers comprehensive guidance regarding the tax implications associated with employment income earned by individuals while serving aboard a ship. Required: Explain whether the following individuals are entitled to an exemption under Paragraph $34,$ Schedule $6$ of the Income Tax Act $($ITA$)1967.$ a$)$ Captain Yusof is the master of a liquefied natural gas $($LNG$)$ carrier, Sagittarius, which is used to transport LNG from Bintulu, Malaysia, to various ports in Japan and China. Sagittarius is operated by Planets Shipping Sdn Bhd $($PMSB$),$ a company that is a resident of Malaysia. PMSB is also the registered owner of the LNG carrier under the MSO $1952.$ In $2024,$ Captain Yusof sailed on Sagittarius for ten months to carry out his duties and was paid USD$100,000.(2$ marks$)$ b$)$ Leo Shipping Sdn Bhd $($LSSB$)$ is a shipping company resident in Malaysia and registered under the MSO $1952.$ LSSB transports agriculture and industrial products from Malaysia to other countries by sea. LSSB charters a tanker$,$ Bright Moon, from a Singaporean company for its business use. Bright Moon sails between Malaysia and Germany. Yasir was employed by Leo Shipping as the First Engineer in Bright Moon's Engine Department. Yasir sailed on Bright Moon for nine months and was paid USD$45,000$ for the voyages. $(3$ marks$)$ Coral Shipping Sdn Bhd is a Malaysian resident company registered under the MSO $1952$ that operates Nile Voyager. This ship sails between ports in Malaysia and Africa, including periodic stops in Asia for cargo operations and crew changes. Ahmad is a marine biologist of Blue Marine Sdn Bhd and was hired to research marine life during Nile Voyager's sails. Ahmad spends most of his time underwater, observing and documenting various species of aquatic animals and plants. Ahmad received RM$70,000$ for his employment. $(2$ marks$)$ d$)$ Ocean Ventures Sdn Bhd $($OVSB$)$ is a Malaysian resident registered under the MSO $1952,$ a shipping company with a diverse fleet of vessels catering to various maritime activities. OVSB owns Marine Rescuer, a specialised rescue vessel equipped for regional maritime search and rescue operations. Yaacob serves as a rescue diver on Marine Rescuer, conducting rescue operations and assisting during maritime emergencies. Marine Rescuer is dedicated to search and rescue missions and is not involved in commercial operations. Yaacob's income is RM$80,000$ annually.