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Singapore Publishes Ruling Summary on Use of Unremitted Foreign Sourced Income to Offset Non-trade Intercompany Debt

|Approved Changes|Singapore
Singapore

The Inland Revenue Authority of Singapore has published Advance Ruling Summary No. 2/2021, concerning whether the use of unremitted foreign-sourced income to offset non-trade intercompany debt constitutes deemed remittance into Singapore. The main parts of the ruling summary are as follows:

Relevant background and facts:

Background

Company A is incorporated and tax resident in Singapore. …

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