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Singapore: Guidance on tax classification of foreign entities, taxation of fees paid to nonresidents under tender offer for qualifying debt securities

Recent guidance from Inland Revenue Authority of Singapore

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January 6, 2026

The Inland Revenue Authority of Singapore (IRAS) released new guidance on classifying foreign entities for Singapore income tax purposes, detailing the factors used to determine whether a foreign entity is treated as a company or a partnership, and providing a published list of selected foreign entity structures and their corresponding classifications.

In addition, the IRAS published Advance Ruling Summary No. 22/2025, confirming that fees paid under a tender offer for qualifying debt securities (QDS) are treated as an early redemption fee or redemption premium under section 13(16) of the Income Tax Act 1947, and are therefore exempt from withholding tax when paid to nonresident holders. Additionally, holders are entitled to the applicable QDS tax exemptions and concessions.


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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