On or about 18 Mar 2022, the Inland Revenue Authority of Singapore (IRAS) has published the Fourth edition of the e-Tax guide, Income Tax: Tax Treatment of Public-Private Partnership Arrangements. It replaces the Third edition published on 22 Feb 2019.

This e-Tax guide explains the approach that the Comptroller of Income Tax (“CIT”) takes to establish the scope of services carried on by the private sector operator involved in a Public Private Partnership (“PPP”) project and provides details on the income tax treatment that would apply.

The scope of a PPP operator’s trade or business will typically fall within one of the following categories –

  1. Operation & Maintenance (“O&M”) service provider;
  2. Finance Lease lessor1 and O&M service provider; or
  3. Design, construction, and O&M service provider.