Singapore: Ruling on income tax issues relating to amalgamation of companies
The ruling confirms that unabsorbed capital allowances and losses of an amalgamating company may be deducted against the income of the amalgamated company.
The Inland Revenue Authority of Singapore (IRAS) issued Advance Ruling Summary No. 7/2026 (May 4, 2026) addressing income tax issues arising from corporate amalgamations.
The ruling confirms that unabsorbed capital allowances and losses of an amalgamating company may be deducted against the income of the amalgamated company under section 34C of the Income Tax Act 1947, subject to the relevant statutory conditions and regulations.
This conclusion is based on the income of the amalgamated company being regarded as arising from the same trade or business as that of the amalgamating company immediately before the amalgamation.
For more information, contact a KPMG tax professional in Singapore:
Audrey Wong | audreywong@kpmg.com.sg