On or about 1 Sep 2020, the Inland Revenue Authority of Singapore (IRAS) has published an Income Tax Advance Ruling Summary No. 10/2020 with regards to “Income tax issues relating to a foreign Limited Partnership”.

The Subject was whether

  1. B Limited Partnership (“B LP”) is a transparent entity for Singapore income tax purposes.
  2. The requirements for Singapore withholding tax on the interest payments made to B LP should depend on the tax residency status of the respective partners of B LP.

The Structure

The Characteristics of Singapore LP and Foreign LP

The Ruling

  1. Based on the characteristics of Foreign LP and the similarities to a Singapore Limited Partnership, B LP is tax transparent for Singapore income tax purposes.
  2. Withholding tax under section 45 of the Income Tax Act is applicable on the portion of the interest payments attributable to partners of B LP who are non-residents of Singapore. The tax residency status of the partners of B LP is to be determined on a year-by-year basis.

For more information about the ruling, please go to the IRAS website.

Source, IRAS, 3 Sep 2020