Singapore Tax Agency Issues Advance Ruling Clarifying Individual Income Taxation of Employees’ Overseas Fund Investments

The Singaporean Inland Revenue Authority April 4 issued Individual Income Tax Advance Ruling No. 2/2025, clarifying the taxation of employee investments in an overseas fund. The taxpayer, a Singapore-based subsidiary of a nonresident private equity company, allowed eligible employees to invest in an overseas limited partnership fund the parent managed. The taxpayer sought clarification on taxation. The Tax Agency clarified in part that: 1) Section 10(6) of Income Tax Act 1947 didn’t apply to the ordinary limited partner shares because they weren’t shares in the taxpayer; 2) taxable benefits the employees derived from acquiring the shares was at the point ...