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