Singapore: Company did not have taxable presence merely by selling goods manufactured locally
The decision highlighted that the company has no fixed place of business or employees in Singapore.
The Inland Revenue Authority of Singapore (IRAS) concluded (Advance Ruling Summary No. 5/2025) that a company did not have a taxable presence in Singapore merely because it sold goods manufactured locally by a related entity and received support services from another foreign related entity's Singapore branch.
The ruling highlighted that the company had no fixed place of business or employees in Singapore, did not maintain inventory in Singapore, and negotiated and concluded contracts outside Singapore. The Singapore branch providing support services had no authority to finalize contracts, and goods delivery was completed by third-party freight forwarders.
For more information, contact a KPMG tax professional in Singapore:
Audrey Wong | audreywong@kpmg.com.sg
Han Swee Peng | sweepenghan@kpmg.com.sg