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

Advance Ruling Summary No. 9/2026

august 11, 2026

The Inland Revenue Authority of Singapore (IRAS) published Advance Ruling Summary No. 9/2026 (July 1, 2026), confirming that a Singapore company acting as a head office, centralized administrative office, and subsidiary management office satisfies the economic substance requirements under Section 10L of the Income Tax Act and qualifies as an excluded entity.

Accordingly, the IRAS ruled that gains derived from the disposal of foreign assets, including gains from the planned sale of an overseas subsidiary, would not be subject to tax under Section 10(1)(g) pursuant to Section 10L(1) when received in Singapore.


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

Audrey Wong | audreywong@kpmg.com.sg

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