Singapore: Tax treatment of consideration received for transfer of certain intellectual property
Advance Ruling Summary No. 11/2025
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