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Singapore: Guidance on economic substance to qualify as an excluded entity for foreign capital gains purposes

Advance Ruling Summary No. 8/2026

July 30, 2026

The Inland Revenue Authority of Singapore (IRAS) published Advance Ruling Summary No. 8/2026 (June 2, 2026) addressing whether a company qualifies as an excluded incentive entity or an excluded entity under Section 10L of the Income Tax Act 1947.

IRAS ruled that the company did not qualify as an excluded incentive entity. However, as it satisfied the economic substance requirements applicable to a non-pure equity-holding entity, its foreign-sourced disposal gains arising from the share transfer would not be taxable when remitted or deemed remitted into Singapore.


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

Audrey Wong | audreywong@kpmg.com.sg

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