The Inland Revenue Authority of Singapore has published Advance Ruling Summary No. 11/2023 on whether the payment of dividends, to be satisfied by the issue of promissory notes, constitutes deemed remittance into Singapore.
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Advance Ruling Summary No. 11/2023
1. Subject:
a. Whether the dividends declared by Company A to Company B, to be satisfied by the issue of the relevant Notes (as defined below) pursuant to the respective payment direction letters (whereby the Notes are kept ent…