A non-exhaustive supplement
The list supports an income-tax advance-ruling application on adequate economic substance under section 10L of the Income Tax Act 1947. It refers to the foreign-asset gains/losses guide for the substantive tests and expressly is not exhaustive. It supplies evidential questions, not numerical headcount or spending thresholds and not an automatic substance exemption.
Group relationships and outsourced activities
Provide a diagram of the relevant group’s holding structure, clearly showing entity relationships for section 10L. For outsourced economic activities, document how the outsourcing entity monitors the provider where the submitted outsourcing agreement does not already capture that information. An agreement naming a provider is different from evidence of actual monitoring.
Singapore-listed REIT applications
Confirm whether the REIT Manager performs core income-generating activity in Singapore; whether the trust deed specifies its functions and responsibilities and termination provisions; whether dedicated resources are set aside for those duties; and whether its service fee is arm’s length. The deed requires both the duties and termination information, not merely the manager’s name.
Private-trust applications
Provide the same four confirmations for the Trustee: Singapore core income-generating activity, deed-defined duties and termination provisions, dedicated resources, and arm’s-length remuneration. The role here is Trustee, rather than automatically the REIT Manager used in the previous category.
Registered business-trust applications
For a Registered Business Trust, those confirmations concern the Trustee-manager: location of core activity, deed functions and termination, resources and arm’s-length fees. Preserve the distinction among the three trust structures and provide documentation consistent with the actual role. The list does not print an application deadline or a promise that supplying these items guarantees a favourable ruling.
Official source
This article independently explains the substantive contents of the official PDF, including the relevant conditions, procedures and annexes. The linked document remains the authoritative source for its original wording, and later changes should be checked separately.
Read the official PDF ↗