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Singapore Advance Ruling on Tax Treatment of Consideration Received in Relation to the Transfer of Certain Intellectual Property

12 October 2022

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Approved Changes

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Singapore

The Inland Revenue Authority of Singapore has published Advance Ruling Summary No. 16/2022, concerning the tax treatment of consideration received in relation to the transfer of certain intellectual property. --- Advance Ruling Summary No. 16/2022 Subject: Whether: The consideration received by Company A from Company B in relation to the transfer of the improvements of licenced Intellectual Property ("Improvements of Licensed IP") related to the business in Territory X should be treated as a capital receipt and hence not subject to tax. Relevant background and facts: Company A is incorporated in Singapore. It operates a manufacturing plant in Singapore and...