Singapore Tax Agency Clarifies Corporate Income Taxation in Corporate Amalgamations

The Singaporean Inland Revenue Authority May 4 posted Advance Ruling Summary No. 7/2026, clarifying corporate income taxation in corporate amalgamations. The taxpayers, Singaporean companies, provided the same type of business support services to their respective subsidiaries and related companies. The taxpayers proposed to amalgamate, with the amalgamated taxpayer continuing the provision of the amalgamating taxpayer’s services after amalgamation. The taxpayers sought clarification on tax treatment. Upon review, the Tax Agency found that: 1) the amalgamating taxpayer’s unabsorbed tax loss items could be deducted against the amalgamated taxpayer’s income under Income Tax Act (ITA), because the former’s income would be considered ...