Background The trustee of a real estate investment trust (REIT) established and listed in Singapore issued a tranche of subordinated perpetual securities (the “Securities”). The Securities possess features that render them hybrid in nature – treated as equity for...

The Inland Revenue Authority of Singapore (IRAS) has issued Advance Ruling Summary No. 2/2026 (dated 2 January 2026) read together with IRAS Advance Ruling Summaries Nos. 7/2025, 10/2025, 14/2025, addressing the economic substance requirements for non-PEHEs. The...

Section 92K of the Income Tax Act 1947 introduces a Listing Corporate Income Tax (CIT) Rebate to incentivise companies to raise public capital and expand economic activities in Singapore. Eligible entities may claim a rebate of either 10% or 20% of their CIT...

This note summarizes the significant judicial developments from six key tax cases decided in 2025, covering capital allowances, the taxation of income from non-performing loans, employment income characterization, the Qualifying Debt Securities (QDS) scheme, the...

Under Sections 23(4) and 37(12) of the Singapore Income Tax Act 1947, a company’s ability to carry forward or carry back unutilised trade losses, capital allowances, and donations is contingent upon meeting the continuity of ownership requirement. A waiver of this...