Advance Ruling System for Income Tax

An advance ruling is a written interpretation of the Income Tax Act 1947 on how certain issues that arise from a proposed arrangement are to be treated for tax purposes. A ruling request has to be one where there are issues that require interpretation of the law, and not one seeking to know what the law clearly provides (e.g. what is the basis period for trade income).

On this page:

Applying for Income Tax Advance Ruling

Under the advance ruling system, taxpayers (including companies, individuals, sole-proprietorships, partnerships, etc.) can make an application for the Comptroller of Income Tax to issue an advance ruling.

More information on the application for advance ruling on the adequacy of economic substance in respect of gains or losses from the sale of foreign assets under Section 10L of the Income Tax Act 1947.

Scope of Income Tax Advance Ruling

An advance ruling only applies to the applicant and the particular arrangement that was the subject of the ruling request and, where applicable, to the year(s) or period(s), and provisions of the Income Tax Act 1947 stated in the ruling. It binds the Comptroller of Income Tax to apply the relevant provisions of the Income Tax Act 1947 in the manner that was set out in the ruling.

Declining a Request/ Application for Advance Ruling

Under certain circumstances, IRAS will not or may decline to rule.

Some examples of circumstances where IRAS will not rule are:

The matter on which the ruling is sought:
- Involves the interpretation of a foreign law or the application of an Agreement for the Avoidance of Double Taxation
- Requires IRAS to form an opinion as to a generally accepted accounting principle or a commercially acceptable practice
IRAS has already raised an assessment (other than an assessment of any estimated tax) for the relevant Year(s) of Assessment in relation to the arrangement
IRAS has embarked on an audit or investigation on how any provision of the Income Tax Act 1947 applies to the company or to other similar arrangements
In IRAS' opinion, the application is frivolous or vexatious¹, or the company is not seriously contemplating the arrangement for which the ruling is sought
The company has not provided sufficient information after IRAS' request for additional information²

Some examples of circumstances where IRAS may decline to rule are:

The matter on which the ruling is sought:
- Require IRAS to determine a question of fact³
- Is subject to an objection or appeal, whether in relation to the company or any other person
- Does not involve interpretation of any provision of the Income Tax Act 1947 and the tax treatment is clearly provided in the law⁴
The correctness of the ruling depends on the making of assumptions, whether in respect of a future event or any other event

View the full list of circumstances (refer to Part 1 of the Seventh Schedule).

Notes

¹IRAS will take into account all surrounding circumstances in considering whether an application is frivolous or vexatious. An instance of a vexatious application is where IRAS views that the proposed arrangement is not carried out for bona fide commercial reasons or involves a scheme which has, as 1 of its main purposes, the avoidance or reduction of tax.

Example of Vexatious Application 1

Company A, a Singapore incorporated company, is the registered owner of a number of trademarks and receives royalty income from its trademarks. Company A plans to set up a wholly owned subsidiary in a low tax jurisdiction to which it will sell all its trademarks. The transfer price is to be paid by the subsidiary from cash flows generated from the operations as and when available. The subsidiary will then receive royalties from the users of the trademarks and will pay dividends from its profits to Company A. Company A claims that the proposed transfer of trademarks is an outright sale for the subsidiary to exclusively focus on owning and managing the trademarks. However, the subsidiary will not have employees and will use the services of an agent in that jurisdiction to handle its incorporation matters.

Ruling request: Confirmation that the gains from sale of trademarks derived by Company A will not be taxed and that future dividends received from the subsidiary will not be taxable in Singapore.

In IRAS' opinion, the proposed transaction is artificial as the transfer price is payable only as and when cash flows generated from the subsidiary's operations are available. The subsidiary appears to be just a shell company with no employees to manage the trademarks. The main purpose of transferring the trademarks to the subsidiary is to avoid or reduce tax payable and not for bona fide commercial reasons.

Example of Vexatious Application 2

Companies X and B are incorporated in Singapore. Company X plans to enter into a distribution agreement with Company B. Company X claims that Company B stipulates that the contracting party of the distribution agreement must be a Singapore incorporated company. Company X does not have employees or operations in Singapore. All of Company X's operations (including the negotiation and signing of the distribution agreement) will be managed and performed by Company Y's employees (on behalf of Company X) in Country Y. Company Y is incorporated in Country Y and is a related party of Company X. The income from reselling the products (arising from the distributing agreement) will be booked in Company X's books. Company X is not able to substantiate why its operations cannot be performed in Singapore.

Ruling request: Confirmation that Company X's income arising from the distribution agreement will be considered sourced outside Singapore and the income will not be subject to tax in Singapore.

In IRAS' opinion, there are no bona fide commercial reasons for having the agreement signed in Country Y and Company Y undertaking the business operations on behalf of Company X, other than for the avoidance or reduction of tax.

² IRAS may decline to rule if the company does not provide the requested information within three months from the date of IRAS’ request for additional information.

³ Example of applications that may require IRAS to determine a question of fact include those seeking IRAS' confirmation on:

The nature and taxability of the gains to be derived from the sale of properties or shares
Whether there was a change of intention with respect to the holding of a property (e.g. from investment holding to property trading or vice versa)
Tax residency status of a company

IRAS will consider the merits of the application on a case-by-case basis and can, at our discretion, decline to make a ruling.

⁴ Example of applications that does not involve interpretation of any provision of the Income Tax Act 1947 (ITA):

	Example	Remarks
1	Whether dividends receivable by Company A from its subsidiary, which is a Singapore tax resident company, will be tax exempt under Section 13(1)(za) of the ITA.	This ruling request does not involve an interpretation of the provision of the ITA as Section 13(1)(za) clearly provides that any dividends paid on or after 1 January 2008 by any company resident in Singapore is exempt from tax.
2	The principal activity of Company A is that of an investment holding company. It has held 80% of the ordinary shares in Company B since Company B’s incorporation in 2019. The business of Company A and Company B are not that of trading or holding of immovable properties. Company A intends to dispose of all the shares in Company B and seeks IRAS' confirmation that the gains from the disposal will qualify for tax exemption under Section 13W of the ITA. Company A confirms that all the conditions in Section 13W have been met.	Section 13W of the ITA clearly stipulates the conditions for the exemption from tax on any gains or profits derived by a company from the disposal of ordinary shares in another company. As the company has confirmed that all the stipulated conditions have been met, the ruling request does not involve any interpretation of the law.
3	Company A has a subsidiary that is incorporated and tax resident in Country X. The headline tax rate and dividend withholding tax rate in Country X is 20% and 10% respectively. Company A seeks IRAS’ confirmation that the conditions for tax exemption under Section 13(8) of the ITA are met in respect of the dividends to be received in Singapore from its subsidiary in Country X.	Whether the dividends qualify for tax exemption under Section 13(8) of the ITA is subject to Company A meeting the conditions for exemption as at the time the dividends are received in Singapore, and the conditions under Section 13(8) are prescriptive. The confirmation sought does not involve an interpretation of the law.

Example

Remarks

Whether dividends receivable by Company A from its subsidiary, which is a Singapore tax resident company, will be tax exempt under Section 13(1)(za) of the ITA.

This ruling request does not involve an interpretation of the provision of the ITA as Section 13(1)(za) clearly provides that any dividends paid on or after 1 January 2008 by any company resident in Singapore is exempt from tax.

The principal activity of Company A is that of an investment holding company. It has held 80% of the ordinary shares in Company B since Company B’s incorporation in 2019. The business of Company A and Company B are not that of trading or holding of immovable properties. Company A intends to dispose of all the shares in Company B and
seeks IRAS' confirmation that the gains from the disposal will qualify for tax exemption under Section 13W of the ITA. Company A confirms that all the conditions in Section 13W have been met.

Section 13W of the ITA clearly stipulates the conditions for the exemption from tax on any gains or profits derived by a company from the disposal of ordinary shares in another company. As the company has confirmed that all the stipulated conditions have been met, the ruling request does not involve any interpretation of the law.

Company A has a subsidiary that is incorporated and tax resident in Country X. The headline tax rate and dividend withholding tax rate in Country X is 20% and 10% respectively. Company A seeks IRAS’ confirmation that the conditions for tax exemption under Section 13(8) of the ITA are met in respect of the dividends to be received in Singapore from its subsidiary in Country X.

Whether the dividends qualify for tax exemption under Section 13(8) of the ITA is subject to Company A meeting the conditions for exemption as at the time the dividends are received in Singapore, and the conditions under Section 13(8) are prescriptive. The confirmation sought does not involve an interpretation of the law.

How to Apply

To obtain an advance ruling from IRAS, you are required to submit an application form along with the required fees and details of the arrangement.

If you are:

Single Applicant: You may apply in your own right or on behalf of a person who has yet to come into legal existence.
Joint Applicants: 2 or more persons may also jointly apply.
Authorised Agent: If an agent is making the ruling request on your behalf, you need to authorise the agent in Section E of the Application form for income tax advance ruling (DOCX, 144KB).

Documents to Submit

Submit the following documents before the date of the proposed arrangement:

Application form for income tax advance ruling (DOCX, 144KB)
A written ruling request providing:

Full particulars of the arrangement in question comprising:
- A comprehensive description of the proposed arrangement and the period concerned
- Background of the parties to the arrangement
- Business reasons for the arrangement, if applicable
- Copies of all relevant documents with the relevant parts or passages identified
The issue(s) to be considered
The propositions of the law that relate to the issues raised in the request. This should include:
- Sections of the Income Tax Act 1947 that are relevant to the request
- Appropriate case laws, if any, and legal reasons that support the applicant's interpretation of the said section(s) involved
- Possible argument contrary to the interpretation proposed and legal reasons and authoritative support, if any, for these arguments
Whether a previous request has been made on the same or similar arrangement. If so, the outcome of the request and reference of the ruling issued, if applicable
A draft ruling

To expedite the review of your ruling request, additional information is required if the arrangement involves a sale of property (PDF, 66KB) or sale of shares (PDF, 59KB). As the matter on which the ruling is sought will require IRAS to determine a question of fact, we can, at our discretion, decline to make a ruling after reviewing the additional information submitted.

Template for Written Ruling Request

You may submit the written ruling request using the template attached as Appendix 1 to the Application form for income tax advance ruling (DOCX, 144KB). We may decline to accept your ruling application if any of the above information is not provided in the written ruling request.

Address your application and ruling request to:

For ruling requests with regard to arrangements concerning Corporate Income Tax matters	Assistant Commissioner (Corporate Tax Division) via email to [email protected]
For ruling requests with regard to arrangements concerning Individual Income Tax matters	Assistant Commissioner (Individual Income Tax Division) via email to [email protected]

Fees Payable

When you apply for an advance ruling, the aggregate of the following fees are payable:

Fees Payable	When to Pay
1. Application fee of S$660 It is non-refundable even if IRAS declines to accept your ruling request. This fee takes into account the time taken to determine if we are able to accept the ruling request.	Payable when submitting the advance ruling application form to IRAS.
2. Further time-based fee You will be charged an hourly rate of S$165 (inclusive of GST) for each hour or part thereof subsequent to the first 4 hours taken to provide the ruling. 3. Additional fee In the exceptional circumstance where we have agreed to the request for express ruling, you will be charged an additional fee (in addition to the application fee and further time-based fee above) of up to 1 time the aggregate of the application fee and further time-based fee above.	If IRAS accepts your ruling application after its review, you will be informed of an estimate of the further time-based fee and additional fee payable (for express rulings) based on the estimated time that IRAS will spend to provide the ruling ('estimated fees') in IRAS’ letter of offer to rule. To facilitate timely collection of such fees, you must pay the estimated fees when you accept IRAS’ offer to provide a ruling. Upon the issue of the ruling or if you withdraw your ruling request after accepting IRAS’ offer to rule, you will be informed of the actual fees payable (based on actual time spent by IRAS) to provide the ruling or process the ruling request up to the point of your withdrawal respectively: Where the actual fees are more than the estimated fees already paid, IRAS will issue an invoice to collect the actual fees in excess of the estimated fees. Payment must be made within 30 days from the date of IRAS’ invoice. Where the actual fees are less than the estimated fees already paid, IRAS will refund you the estimated fees paid in excess within 15 working days after IRAS informs you of the actual fees, provided that all information for a refund via interbank transfer has been made available to IRAS.
4. Reimbursement fee Any costs and reasonable disbursements incurred by IRAS in relation to the ruling and any fees paid by us for external professional advice must be reimbursed by the applicant. We will seek your agreement before obtaining any external professional advice.	Payable within 30 days from the date of IRAS’ invoice which will be sent to you.

Fees Payable

When to Pay

1. Application fee of S$660

It is non-refundable even if IRAS declines to accept your ruling request. This fee takes into account the time taken to determine if we are able to accept the ruling request.

Payable when submitting the advance ruling application form to IRAS.

2. Further time-based fee

You will be charged an hourly rate of S$165 (inclusive of GST) for each hour or part thereof subsequent to the first 4 hours taken to provide the ruling.

3. Additional fee

In the exceptional circumstance where we have agreed to the request for express ruling, you will be charged an additional fee (in addition to the application fee and further time-based fee above) of up to 1 time the aggregate of the application fee and further time-based fee above.

If IRAS accepts your ruling application after its review, you will be informed of an estimate of the further time-based fee and additional fee payable (for express rulings) based on the estimated time that IRAS will spend to provide the ruling ('estimated fees') in IRAS’ letter of offer to rule.

To facilitate timely collection of such fees, you must pay the estimated fees when you accept IRAS’ offer to provide a ruling.

Upon the issue of the ruling or if you withdraw your ruling request after accepting IRAS’ offer to rule, you will be informed of the actual fees payable (based on actual time spent by IRAS) to provide the ruling or process the ruling request up to the point of your withdrawal respectively:

Where the actual fees are more than the estimated fees already paid, IRAS will issue an invoice to collect the actual fees in excess of the estimated fees. Payment must be made within 30 days from the date of IRAS’ invoice.
Where the actual fees are less than the estimated fees already paid, IRAS will refund you the estimated fees paid in excess within 15 working days after IRAS informs you of the actual fees, provided that all information for a refund via interbank transfer has been made available to IRAS.

4. Reimbursement fee

Any costs and reasonable disbursements incurred by IRAS in relation to the ruling and any fees paid by us for external professional advice must be reimbursed by the applicant. We will seek your agreement before obtaining any external professional advice.

Payable within 30 days from the date of IRAS’ invoice which will be sent to you.

You can pay via Internet Banking Fund Transfer/ Telegraphic Transfer to IRAS' bank account as stated below:

Description	Details
Payee	Inland Revenue Authority of Singapore
DBS Current Account Number	0010516000 - SGD
DBS Bank/ Branch Code	7171/ 001
DBS Bank Swift Code	DBSSSGSG

Indicate the UEN number and/or applicant's name under the Beneficiary Reference/ Purpose of Payment/ Remittance Information/ Payment Details field to avoid delay in the processing of the application.

Application Review Process

Applications may or may not be accepted.

Application Accepted

You will be informed when you can expect the ruling to be issued and the estimated amount of total fees payable. You will be required to confirm in writing your acceptance of the terms under which the ruling is to be issued.

Generally, we will give a ruling within 8 weeks of receiving all necessary information. Where the ruling request relates solely to the adequacy of economic substance under Section 10L of the Income Tax Act 1947, we will give a ruling within 4 weeks of receiving all the necessary information. If the request is complex and we require more time, we will keep you informed.

Application Not Accepted

You will be informed of the non-acceptance and the reason(s). The application fee of S$660 will not be refunded.

Applications for rulings are generally processed on a first-come-first-serve basis. An overview of the application review process is as follows:

	Activity	Remarks
1	IRAS receives advance ruling application via email	IRAS will acknowledge receipt of the application via email within 3 working days of receipt of the application.
2	IRAS issues first query letter with a view to accept the application/ IRAS rejects the application¹	Within 6 weeks of receipt of application. After reviewing the application, IRAS may write to you or your authorised tax agent for additional information to process your ruling request. We will process your ruling request only when the additional information has been submitted. To help us expedite the review of your application, ensure that you provide complete/ detailed information in your ruling requests.
3	IRAS receives Applicant's reply
4	IRAS issues second query letter	Within 6 weeks of receipt of first reply.
5	IRAS receives Applicant's reply
6	IRAS issues letter of offer and informs Applicant of the estimated fees to provide a ruling/ IRAS rejects the application	Within 6 weeks of receipt of second reply. IRAS assumes that full information has been made available at this stage. If otherwise, IRAS reserves the right to request for further information.
7	IRAS receives Applicant's acceptance of offer letter and payment for the estimated fees
8	IRAS issues advance ruling	Within 8 weeks (or 4 weeks if the ruling request relates solely to the adequacy of economic substance under Section 10L of the Income Tax Act 1947) from date of receipt of acceptance letter, payment for the estimated fees or complete information, whichever is later.

¹ IRAS may decline to give a ruling/ will not give a ruling if the application falls within paragraphs 1, 2 and/or 3 of Part I of the Seventh Schedule of the Income Tax Act 1947 or the information in the ruling application is incomplete.

Express Rulings

As applicants are generally in the position to plan and put in an advance ruling application, IRAS does not agree to requests for express rulings except in exceptional circumstances where there are good and valid reasons, and only if IRAS' resources permit. IRAS does not accept the following reasons (non-exhaustive) as grounds for express rulings:

The ruling is required to finalise the proposed structure/ transaction so that the applicant can proceed with the next steps
The listing of the proposed structure/ proposed transaction is targeted to take place soon
The ruling is required to obtain certainty of the tax treatment of the proposed transaction before the filing of the Income Tax Return/ completion of a deal/ Board meeting

In the exceptional circumstance where IRAS agrees to a request for an express ruling, we will issue the advance ruling within 6 weeks from the date of receipt of acceptance letter or complete information, whichever is later.

Withdrawing Your Application

You can withdraw your ruling request any time before the ruling is given. The withdrawal must be made in writing.

Withdrawing before the confirmation of your acceptance

If you withdraw before the ruling is given and before you confirm in writing your acceptance of the terms under which the ruling is to be issued, no other fees are payable. The application fee of S$660 will not be refunded.

Withdrawing after the confirmation of your acceptance

If you withdraw after you confirm in writing your acceptance of the terms under which the ruling is to be issued but before the ruling is given, you will be charged the further time-based fee, additional fee (for express rulings) and reimbursement fee (if any) for the time spent on the review of your ruling request up to the time of receipt of your withdrawal. These fees are on top of the application fee of S$660.

Learn when to pay the above fees chargeable to you.

Contact Information

You may contact us for assistance or clarification on the advance ruling system for income tax:

Arrangement that involves	Contact details
Individual Income Tax	[email protected]
Corporate Income Tax	[email protected]

Upon Issuance of Income Tax Advance Ruling

Disagreeing with Income Tax Advance Ruling

An advance ruling is final and the taxpayer cannot appeal against the ruling i.e. there is no appeal process provided for in the Income Tax Act 1947.

If you disagree with the ruling, you must declare in your annual Income Tax Return for the relevant Year of Assessment that you have obtained and chosen not to rely on the advance ruling. IRAS will review the difference in opinion when we review your Income Tax Return. You may appeal against any assessment raised on the basis of our advance ruling under the objection provisions in Section 76(2) of the Income Tax Act 1947.

Publishing Income Tax Advance Rulings

IRAS issues e-Tax Guides and updates our website to set out our views on the tax treatment of general tax issues.

Where useful or appropriate, IRAS will include examples modified from advance rulings in the e-Tax Guides and on our website to provide greater tax certainty and transparency on IRAS interpretation of tax laws. You may wish to refer to these publications before making an advance ruling application.

In addition, to enhance taxpayers’ understanding of IRAS’ interpretation and application of tax laws in specific scenarios, we will publish a summary of the ruling (i.e. a summary of the background, facts and issues raised in the application for advance ruling, as well as the rulings given) on IRAS’ website in respect of advance ruling applications made on or after 1 May 2019, if:

You have given your consent for the publication of a summary of the ruling in Section E of the advance ruling application form; and
The issue that is the subject of the ruling request does not relate to any Advance Pricing Arrangement.

For advance ruling applications made on or after 1 Feb 2021 where the subject of the ruling request relates to the characterisation of hybrid instrument and related issues, IRAS may exclude the ruling from publication if similar summaries of ruling have been published on IRAS’ website.

The summary of the ruling will be published in a form that does not set out the identity of the applicant, the arrangement or any other parties to the arrangement in the ruling, date of transactions or transaction values. View the sample format (PDF, 283KB) of an advance ruling that will be published.

Timelines for Publication of Advance Rulings

A summary of the ruling will be published on our website based on the following timelines:

At least 6 months after the ruling has been issued, for advance ruling applications made before 1 June 2023; and
At least 9 months after the rulings has been issued, for advance ruling applications made on or after 1 June 2023.

Prior to publication, we will provide you with a draft copy of the summary of the ruling for your comments within 8 weeks from the date of the ruling letter. You must review the draft summary carefully and notify IRAS of any proposed edits (with reasons) within 6 weeks. We will consider any comments and proposed changes made by you before the publication of the summary. No fee is chargeable for the time spent in preparing the summary of the ruling for publication.

The expected timeline for the publication of an advance ruling is as follows:

	Activity	Remarks
1	IRAS issues ruling to Applicant
2	IRAS sends first summary of ruling to Applicant for review and agreement	Within 8 weeks from date of ruling letter
3	Applicant to reply to IRAS with proposed edits and reasons for the edits, or confirmation that no edit is required	Within 6 weeks from the date IRAS sends the first summary^{1 2}
4	IRAS sends second summary of ruling to Applicant for review and agreement	Within 6 weeks from the receipt of applicant’s reply on the first summary
5	Applicant to reply to IRAS with proposed edits and reasons for the edits, or confirmation that no edit is required	Within 6 weeks from the date IRAS sends the second summary^{1 2}
6	IRAS uploads the summary of ruling on IRAS website	At least 6 months after the ruling is issued to the Applicant for advance ruling applications made before 1 June 2023 At least 9 months after the ruling is issued to the Applicant for advance ruling applications made on or after 1 June 2023

¹ If a reply is not received by the timeline mentioned, IRAS may proceed to upload the ruling summary on the IRAS website after 6 months or 9 months (as the case may be) from the date of the ruling.

² IRAS may consider requests for extension of time to reply on the summary on a case-by-case basis. Such extensions are to be requested for at least 1 week before the original deadline lapses.

Summary of Income Tax Advance Rulings Issued

Individual Income Tax

Publication Date	Title
28 Aug 2024	Whether profits derived by a partnership from the proposed sale of the business to a company is capital in nature (PDF, 97KB)
25 Jul 2023	Whether any gains or profits derived under the management incentive plan by the subscription members will be deemed to be taxable under section 10(6) at the time when the subscription member subscribes for and is issued with the Class X Shares under the plan (PDF, 21KB)
25 Jul 2023	Whether the entitlement of the additional share awards upon the stock split constitutes a new grant of a right or benefit to acquire shares (PDF, 18KB)
16 Dec 2022	Whether the interest income earned by Singapore resident individuals or by beneficiaries of a Singapore trust from investing in interest-bearing Notes offered by a section 13O Fund is exempt from income tax (PDF, 281KB)
23 Aug 2022	Whether the gains/profits derive from the shares to be issued to employees under a proposed Partner Equity Plan fall to be taxable at the time when the employees acquired the shares or later (PDF, 345KB)
30 Jun 2021	Whether the interest income earned by Singapore resident individuals from investing in interest-bearing Notes offered on the Company's online platform is exempt from income tax under Section 13(1)(ze)(i) of Income Tax Act (Cap. 134, 2014 Revised Edition) (PDF, 286KB)
30 Jun 2021	Whether the conversion of Restricted Stock Units granted under a Stock Incentive Plan following a separation event would be taxable on the employees under Section 10(6) of the Income Tax Act (Cap. 134, 2014 Revised Edition) (PDF, 272KB)
21 May 2021	Whether Section 10(6) of Income Tax Act (Cap. 134, 2014 Revised Edition) is applicable to shares subscribed by employees under a leveraged share plan (PDF, 277KB)

Other than Individual Income Tax

Publication Date	Title
1 Nov 2024	Characterisation of hybrid instrument and related issues (PDF, 118KB)
1 Nov 2024	Withholding tax treatment of discount on the sale of trade receivables (PDF, 91KB)
1 Oct 2024	Characterisation of hybrid instrument and related issues (PDF, 132KB)
1 Apr 2024	Tax treatment of proposed transfer of the Properties (PDF, 129KB)
1 Apr 2024	Tax transparency treatment on the income from the sale of electricity derived by a real estate investment trust (PDF, 108KB)
1 Apr 2024	Tax treatment of Exchange Fee paid pursuant to exchange of Existing Notes (PDF, 96KB)
1 Mar 2024	Tax treatment of liquidation proceed (PDF, 104KB)
1 Dec 2023	Whether tax deferred distributions derived from a foreign trust would be subject to Singapore income tax (PDF, 105KB)
1 Dec 2023	Tax treatment of initial and subsequent gains derived from the sale of shares (PDF, 111KB)
4 Sep 2023	Tax treatment of tender premium in respect of notes accepted for purchase by the issuer of the notes (PDF, 116KB)
4 Sep 2023	Whether the payment of dividends, to be satisfied by the issue of promissory notes, constitutes deemed remittance into Singapore (PDF, 119KB)
1 Aug 2023	Tax treatment of gains from disposal of shares (PDF, 130KB)
3 Jul 2023	Income tax issues relating to transfer of business (PDF, 118KB)
1 Jun 2023	Tax treatment of certain income and expense under the shipping incentive (PDF, 113KB)
1 Jun 2023	Tax treatment of tender fees payable on notes offered for sale and accepted for purchase by the issuer of the notes (PDF, 161KB)
1 Jun 2023	Tax treatment of tender fees payable on notes accepted for purchase by the issuer of the notes (PDF, 124KB)
1 May 2023	Whether Singapore withholding tax is applicable on certain payments made under an agreement (PDF 114KB)
2 May 2023	Tax treatment of gains from disposal of shares (PDF 136KB)
1 Mar 2023	Tax treatment of sale of investment (PDF 106KB)
1 Mar 2023	Tax treatment of tender fees payable on notes offered for sale and accepted for purchase by the issuer of the notes (PDF, 114KB)
3 Jan 2023	Tax treatment of gain on transfers of partial interest in property and date of conversion of remaining interest in property from a capital asset to trading stock (PDF, 121KB)
1 Dec 2022	Characterisation of redeemable preference shares and related issue (PDF, 134KB)
1 Nov 2022	Tax treatment of liquidation proceeds (PDF, 110KB)
3 Oct 2022	Tax treatment of consideration received in relation to the transfer of certain intellectual property (PDF, 83KB)
1 Aug 2022	Income tax issues relating to shipping pool arrangement (PDF, 120KB)
1 Aug 2022	Tax treatment of tender premium in respect of notes accepted for purchase by issuer (PDF, 111KB)
1 Aug 2022	Characterisation of hybrid instrument and related issues (PDF, 135KB)
1 Aug 2022	Characterisation of hybrid instrument and related issues (PDF, 133KB)
1 Jul 2022	Applicability of previous advance rulings (relating to characterisation of hybrid instruments and related issues) subsequent to amendments pursuant to consent solicitation exercise and other amendments (PDF, 102KB)
1 Jun 2022	Whether a non-resident company has a taxable source in Singapore by virtue of its activities performed in Singapore and withholding tax treatment on technical service fees (PDF, 20KB)
1 Jun 2022	Tax treatment of sale of fixed assets (PDF, 17KB)
1 Jun 2022	Income tax issues relating to transfer of business and the applicability of Section 24 of the Income Tax Act 1947 (2020 Revised Edition) in respect of the plant and machinery transferred (PDF, 122KB)
4 May 2022	Taxability of gain on sale of investment (PDF, 41KB)
4 May 2022	Characterisation of redeemable preference shares and related issue (PDF, 30KB)
1 Apr 2022	Characterisation of hybrid instrument and related issues (PDF 55KB)
1 Mar 2022	Characterisation of hybrid instrument and related issues (PDF, 50KB)
4 Feb 2022	Characterisation of hybrid instrument and related issues (PDF, 52KB)
3 Jan 2022	Tax treatment of security token (PDF, 89KB)
3 Jan 2022	Tax treatment of the gross proceeds derived from the disposal of certain investment for the purpose of Section 13X of the Income Tax Act (Cap. 134, 2014 Revised Edition) (PDF, 44KB)
1 Oct 2021	Characterisation of hybrid instrument and related issues (PDF, 53KB)
1 Oct 2021	Characterisation of hybrid instrument and related issues (PDF, 51KB)
1 Oct 2021	Characterisation of hybrid instrument and related issues (PDF, 51KB)
1 Oct 2021	Tax treatment of tax deferred distributions by unitholder (PDF, 49KB)
1 Sep 2021	Tax treatment of exchange fee paid pursuant to exchange of Notes (PDF, 22KB)
1 Sep 2021	Whether the use of an amount receivable from a related company which was made up of unremitted foreign-sourced income for a share capital reduction exercise and payment of a service fee constitutes a remittance or deemed remittance into Singapore (PDF, 45KB)
1 Sep 2021	Characterisation of hybrid instrument and related issues (PDF, 58KB)
1 Sep 2021	Characterisation of hybrid instrument and related issues (PDF, 30KB)
2 Aug 2021	Income tax issues relating to amalgamation of companies (PDF, 23KB)
2 Aug 2021	Characterisation of hybrid instrument and related issues (PDF, 24KB)
1 Jul 2021	Characterisation of hybrid instrument and related issues (PDF, 42KB)
1 Jun 2021	Tax treatment of sale of investment (PDF, 21KB)
3 May 2021	Characterisation of hybrid instrument and related issues (PDF, 52KB)
3 May 2021	Characterisation of hybrid instrument and related issues (PDF, 31KB)
1 Apr 2021	Source of franchise income (PDF, 47KB)
1 Feb 2021	Whether the use of unremitted foreign sourced income to offset non-trade intercompany debt constitutes deemed remittance into Singapore (PDF, 50KB)
4 Jan 2021	Related party for Singapore transfer pricing purposes (PDF, 30KB)
1 Dec 2020	Characterisation of hybrid instrument and related issues (PDF, 28KB)
1 Dec 2020	Withholding tax on payments made pursuant to license agreement (PDF, 46KB)
1 Dec 2020	Withholding tax on art performance fees (PDF, 43KB)
2 Nov 2020	Whether the use of unremitted foreign sourced income towards capital reduction constitutes deemed remittance into Singapore (PDF, 52KB)
1 Sep 2020	Income tax issues relating to a foreign Limited Partnership (PDF, 35KB)
1 Sep 2020	Characterisation of hybrid instrument and related issues (PDF, 31KB)
3 Aug 2020	Characterisation of hybrid instrument and related issues (PDF, 30KB)
3 Aug 2020	Characterisation of hybrid instrument and related issues (PDF, 48KB)
30 Jun 2020	Characterisation of hybrid instrument and related issues (PDF, 29KB)
30 Jun 2020	Characterisation of hybrid instrument and related issues (PDF, 49KB)
30 Jun 2020	Tax treatment of exchange fee paid pursuant to exchange of Notes (PDF, 47KB)
30 Jun 2020	Tax treatment of expenditure incurred to acquire a new business (PDF, 17KB)
30 Apr 2020	Characterisation of hybrid instrument and related issues (PDF, 55KB)
30 Apr 2020	Characterisation of hybrid instrument and related issues (PDF, 55KB)

Spontaneous Exchange of Information

Singapore participates under an internationally agreed framework for the compulsory spontaneous exchange of information in respect of rulings. Under the framework, Singapore will spontaneously exchange information on specified categories of rulings with certain jurisdictions.

Learn more about the Spontaneous Exchange of Information.