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Taxes · PDF

Corporate Ruling 4/2026: Sale of Owner-Occupied Office Floors

Ruling 4/2026 finds a related-party sale of substantially owner-used office floors to be capital after considering acquisition intent, use, holding period and financing.

Source checked · 11 October 2026 · Document date: 02 Mar 2026 Advance ruling · case-specific

Office premises and purpose of disposal

Singapore-incorporated Company A carries on business in Singapore and owns several floors acquired for office use. It consistently maintained that intention and substantially used the premises itself. No loan or debt financed the acquisition, and it recorded the property as property, plant and equipment under FRS 16 at acquisition. The property is sold to related Company B, with proceeds intended to improve A’s solvency.

Four factors and conclusion

The summary published on 2 March 2026 identifies section 10(1) and rules the sale a capital transaction. The reasons consider acquisition intention, use, holding period and financing method together. The summary does not disclose a numerical holding period or create an exemption merely because the buyer is related or the asset is classified as PPE in the accounts.

General reference and limits

The publication directs readers to IRAS’s trade-determination factors on the taxable/non-taxable corporate-income webpage. It binds only this applicant and transaction; similar cases are not automatically bound to the same outcome, and published rulings are not updated for later law or interpretation changes.

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 ↗
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