The Inland Revenue Authority of Singapore has published Advance Ruling Summary No. 11/2020, concerning whether the use of unremitted foreign-sourced interest income towards a capital reduction exercise constitutes a deemed remittance into Singapore under section 10(25) of the Income Tax Act. The main parts of the ruling summary are as follows: Relevant background and facts: Background The Company is incorporated and tax resident in Singapore. It carries on a trade in Singapore. It is a wholly-owned subsidiary of ABC, a company incorporated and tax resident in Country A. Loans to related entities by the Company To meet funding needs within...