Licensed online funding platform
Published 30 June 2021, this case involves a Singapore company with an MAS Capital Markets Services Licence under the Securities and Futures Act. Its platform connects Singapore SMEs seeking funding with investors buying approved interest-bearing notes. Registered businesses list notes after company approval; investors choose a note and funding amount, and the issuer pays interest. Both issuers and investors must maintain identified user accounts.
Features supporting securities classification
For each subscribed note the platform company issues one Investment Note Certificate on behalf of the issuer covering all participating investors. Every note has a unique code; each investor’s e-wallet stores accessible note details. The instruments can be traded or transferred, and another party, including the platform company, can legally acquire them. Multiple-investor funding and transferability underpin IRAS’s classification as debt securities.
Exemption and exclusions
The ruling applies section 13(1)(ze)(i) of the Income Tax Act, Revised Edition 2014, to interest earned by Singapore-resident individuals on these notes. It excludes interest derived through a Singapore partnership or from carrying on a trade, business or profession. Section 13(16) adopts the section 43N debt-securities meaning; section 43N(4) covers categories including bonds, notes, commercial paper, treasury bills, deposit certificates and ATI instruments under 10O(2). The case does not grant all platform users, businesses or unlicensed lending products a blanket exemption.
Historical case boundaries
The ruling binds only its applicant and specified arrangement, and IRAS does not update published summaries when legislation or interpretations change. Keep the 2021 date and the stated statutory edition when using it as a case study rather than describing it as a new general platform rule.
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 ↗