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Singapore Advance Ruling on Withholding Tax Treatment of Discounts on the Sale of Trade Receivables

04 November 2024

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Approved Changes

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Singapore

The Inland Revenue Authority of Singapore has published Advance Ruling Summary No. 6/2024 on the withholding tax treatment of discounts on the sale of trade receivables. Advance Ruling Summary No. 6/2024 1. Subject: a. Whether the "discount" on Company A's sale of trade receivables to banks, being non-tax resident persons, in discounting arrangements fall within the meaning of section 12(6)(a)(i) of the Income Tax Act 1947 ("ITA"). 2. Relevant background and facts: a. Company A is in the business of trading in commodities. It is incorporated and tax resident in Singapore. b. In the course of its trading activities, Company...