Singapore Tax Agency Issues Advance Ruling on Corporate Income Taxation of Intellectual Property Improvement Transfers

The Singaporean Inland Revenue Authority June 2 issued Advance Ruling No. 11/2025, clarifying the corporate income tax treatment of transfers of intellectual property (IP) improvements. A Singaporean manufacturer was in a group with another company. The companies agreed to terminate their license agreement that granted the manufacturer certain IP rights. The manufacturer then transferred all its legal and economic ownership of an improvement IP to the other company for consideration. The Tax Agency ruled that the transfer was a nontaxable capital receipt because: 1) the manufacturer didn’t regularly transfer rights, title, or interests in improvement IP in the ordinary course ...