Singapore Tax Agency Issues Advance Ruling on Taxation of Foreign-Sourced Dividend Income

The Singaporean Inland Revenue Authority Sept. 4 issued Advance Ruling Summary No. 11/2023, clarifying the taxation of foreign-sourced dividend income. An investment holding company, resident in Singapore, held shares in a company incorporated outside of Singapore, which intended to declare dividends payable to the resident company. The payments were to be made through promissory notes and by subsequent dividend declarations to the resident company’s ultimate shareholder, an entity incorporated outside of Singapore. The tax agency clarified that: 1) dividends settled through the issuance of notes wouldn’t be regarded as received in Singapore, and therefore wouldn’t be taxable in Singapore; and ...