Singapore Tax Agency Issues Advance Ruling on Income Tax Treatment of Novation in Group Restructuring

The Singaporean Inland Revenue Authority May 2 issued Advance Ruling No. 6/2025, clarifying the corporate income tax treatment of a novation of agreements in a group restructuring. A group company’s agreements would be novated to a second company in the group in a group restructuring in exchange for a promissory note. The first company entered into the agreements without intending to trade in them, and there was no profit-seeking motive at the time of novation. The novation was to comply with an authority’s directive. The Tax Agency ruled that the novation was a capital transaction and is not subject to ...