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 w…