Further to the decision of the Income Tax Board of Review (ITBR) in the case of AQQ v. The Comptroller of Income Tax ([2011] SGITBR1), the High Court decision has become available. The main issues before the High Court were whether the ITBR had applied the correct approach in applying section 33 of the Income Tax Act (ITA) (the general anti-avoidance rule (GAAR)), and whether the financing arrangement was covered by the GAAR. In line with the decision and grounds of the ITBR, the High Court found that Singapore's GAAR did apply to the financing arrangement and that the financing arrangement involved...