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Singapore Advance Ruling on the Tax Treatment of the Disposal of Management Shares in a Special Investment Vehicle

04 May 2023

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Approved Changes

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Singapore

The Inland Revenue Authority of Singapore has published Advance Ruling Summary No. 4/2023, concerning the tax treatment of the sale of management shares held in a special purpose vehicle. --- Advance Ruling Summary No. 4/2023 Subject: Whether the gains arising from disposal of Management Shares (defined below) held in Special Purpose Vehicle ("SPV") A and SPV B (collectively, the "Funds") by Company A to Company Z would be capital in nature and not subject to tax under the Income Tax Act 1947 (2020 Revised Edition) ("ITA"). Relevant background and facts: Company A is a Singapore tax resident. SPV A and...