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Taxes · PDF

Section 10L Economic Substance: Additional Advance-Ruling Information

The checklist focuses on group relationships, outsourcing oversight and trust-manager resources.

Source checked · 11 October 2026 Advance ruling · case-specific

Explain the group and outsourcing

Provide a holding-structure diagram identifying the relevant group relationships. When activities are outsourced, document how the entity monitors the outsourced work if the agreement itself does not record that supervision. The information supplements the foreign-asset gains guide and advance-ruling request; it is expressly non-exhaustive. A contract naming a Singapore service provider is therefore not, alone, the entire evidence for adequate economic substance.

Trust structures need specific confirmations

For listed REITs, private trusts and registered business trusts, explain whether core income-generating activity occurs through the manager, trustee or trustee-manager in Singapore. Confirm trust-deed responsibilities and termination terms, dedicated resources and arm’s-length fees. These confirmations concern actual functions and resources, not merely an address or title. Supply the facts relevant to the specific entity and requested ruling rather than treating every checklist item as applicable to every company.

Official source

A concise, independent Apex Gateway guide based on the official English source, not a reproduction of the complete document. Consult the original for full conditions, exceptions and subsequent updates. Published rulings bind only the applicant and specified transaction. IRAS does not update them for later changes in law or interpretation.

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