On 11 July 2016, the Inland Revenue Authority of Singapore (IRAS) published a first edition e-Tax guide on the general anti-avoidance provision in section 33 of the Income Tax Act (ITA) and its application. Arrangements Subject to Section 33 The general anti-avoidance provision applies to avoidance arrangements falling in four groups: Circular flow or round-tripping of funds; Setting-up of more than one entity for the sole purpose of obtaining tax advantage; Change in business form for the sole purpose of obtaining tax advantage; and Attribution of income that is not aligned with economic reality. The general anti-avoidance provision does not...