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Singapore Advance Ruling on Income Tax Issues Relating to the Transfer of a Business

12 March 2025

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Approved Changes

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Singapore

The Inland Revenue Authority of Singapore has published Advance Ruling Summary No. 3/2025 on income tax issues relating to the transfer of a business. --- Advance Ruling Summary No. 3/2025 1. Subject: a. Whether the proposed transfer of the entire banking business of Bank A to a new Singapore branch (the "Transferee") of a foreign bank ("Bank B") is treated as a capital transaction and any gains arising therefrom should not result in any income tax liability to Bank A under the Income Tax Act 1947 (the "ITA"). 2. Relevant background and facts: a. Relevant background and facts: Bank A...