Singapore Tax Agency Issues Advance Ruling Clarifying Taxation of Capital Gains From Property Transfers

The Singaporean Inland Revenue Authority Aug. 1 issued Advance Ruling Summary No. 16/2025, clarifying the income tax treatment of capital gains from property interest transfers. The taxpayer, a Singaporean parent company, planned to transfer investment properties to its new, wholly-owned subsidiaries in Singapore pursuant to an intra-group restructuring. The taxpayer sought clarification regarding whether gains arising from the transfer were taxable under the Income Tax Act 1947 (ITA). Upon review, the Tax Agency found that: 1) the proposed transfer would be considered a capital transaction given the holding period of the properties, the taxpayer’s use of the properties, the frequency ...