Singapore Tax Agency Issues Advance Ruling on Tax Treatment of Gains From Transfer of Shares

The Singaporean Inland Revenue Authority Dec. 2 issued Advance Ruling No. 8/2024, on the tax treatment of gains from the transfer of shares in a subsidiary. The taxpayer, A Singaporean company, sought clarification on the tax implications of transferring shares in its wholly owned subsidiary. The tax authority clarified that: 1) the taxpayer didn’t qualify for the tax exemption under Section 13W of the Income Tax Act (ITA) because the subsidiary engaged in property development within 60 months before the sale, which disqualified it under Section 13W(8)(ba)(iii)(B); and 2) because the transfer is considered a capital transaction, based on factors ...