Section 10L Changes the Singaporean Tax Landscape for MNEs

Recent amendments to Singaporean tax law may increase the Singaporean tax liability of multinational groups that are engaging in routine asset sales and restructuring transactions, even when the transactions otherwise lack nexus with Singapore. Historically, Singapore did not tax capital gains. Singapore also did not tax foreign source income even when repatriated to Singapore in the form of dividends if those dividends qualified for a statutory tax exemption (See Income Tax Act 1947 (“ITA”), Section 13(8)). Thus, a Singaporean company could sell or otherwise transfer intellectual property (“IP”) to a subsidiary, the subsidiary could use the IP to derive ...