The Inland Revenue Authority of Singapore has published Advance Ruling Summary No. 3/2021, concerning whether franchise income derived by a company is sourced outside Singapore and is taxable only upon remittance or deemed remittance to Singapore under the provisions of the Income Tax Act. The main parts of the ruling summary are as follows: Relevant background and facts: Group X is one of the world's largest technology suppliers in certain industry. Group X currently has a subsidiary, Company B, that owns the legal and economic rights to certain intellectual property ("IP") and other intangible properties. Company B has entered into...