Singapore: Tax treatment of consideration received for transfer of certain intellectual property

Advance Ruling Summary No. 11/2025

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August 25, 2025

The Inland Revenue Authority of Singapore (IRAS) published Advance Ruling Summary No. 11/2025, concluding that the consideration received by Company A from Company B for the transfer of improvements of licensed intellectual property is a capital receipt, and thus not taxable.

The transfer was part of a group restructuring, and not a regular business activity of Company A, with no compensation received for terminating the license agreement, hence supporting its classification as a non-revenue transaction.


For more information, contact a KPMG tax professional in Singapore:

Audrey Wong | audreywong@kpmg.com.sg

Han Swee Peng | sweepenghan@kpmg.com.sg

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