Anti-Avoidance and Revenue Protection

(a) General anti-avoidance rules

Singapore's anti-avoidance legislation empowers the Tax Comptroller to disregard and to vary and make adjustments to certain arrangements which are carried out for the purpose of tax avoidance and not for bona fide commercial reasons.

(b) Dual-resident companies

There are no provisions in Singapore's tax legislation to resolve an issue surrounding dual residence of a company. A company is regarded as resident in Singapore for tax purposes if it has its management and control in Singapore. Tax treaties concluded by Singapore generally resolve any issue of dual residence.

(c) Tax shelter disclosure rules

There are no tax shelter disclosure rules in Singapore's legislation.

(d) Treaty shopping

There are no anti-treaty shopping provisions in Singapore's legislation. Generally, Singapore's tax treaties include anti-treaty shopping provisions.

(e) Thin capitalization rules

Singapore companies are not subject to thin capitalization rules.

(f) Transfer pricing rules

Singapore companies are subject to transfer pricing rules.

(g) Controlled foreign companies

Singapore does not impose controlled foreign company (CFC) rules on corporate taxpayers.