The Inland Revenue Authority of Singapore has published Advance Ruling Summary No. 11/2023 on whether the payment of dividends, to be satisfied by the issue of promissory notes, constitutes deemed remittance into Singapore. --- Advance Ruling Summary No. 11/2023 1. Subject: a. Whether the dividends declared by Company A to Company B, to be satisfied by the issue of the relevant Notes (as defined below) pursuant to the respective payment direction letters (whereby the Notes are kept entirely outside Singapore), will be regarded as received in Singapore under section 10(25) of the Income Tax Act 1947 (2020 Revised Edition) (the...