The Inland Revenue Authority of Singapore has published Advance Ruling Summary No. 2/2021, concerning whether the use of unremitted foreign-sourced income to offset non-trade intercompany debt constitutes deemed remittance into Singapore. The main parts of the ruling summary are as follows: Relevant background and facts: Background Company A is incorporated and tax resident in Singapore. Company A and Company B are both investment-holding companies. Company B is incorporated and tax resident outside Singapore. Company A and Company B are wholly owned by Company C, a company incorporated and tax resident outside Singapore and publicly listed outside Singapore. Company A, B...