Singapore: Guidance on economic substance to qualify as an excluded entity for foreign capital gains purposes
Advance Ruling Summary No. 8/2026
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