Separate sources and basis periods
The template is a guide for investment holding plus routine related-party support listed in Annex C of Transfer Pricing Guidelines. Record tax reference/name/YA/basis period. Service income deducts direct costs adjusted under sections 14/15, allocated statutory/regulatory and other expenses, then capital allowances. Dividend, interest and other income each deduct their own direct and allocated costs. A preceding-year basis means YA 2023 uses 1 April 2021–31 March 2022 for March year-end, or calendar 2022 for December year-end.
Expenses and schedules
Allocate shared statutory/regulatory and general directors/admin/management expenses by relevant income divided by total income. Direct revenue expenses must relate to income-producing investments. As a guide other allowable expenses against investment income should not exceed 5% of gross investment income; this is not a 5% cap on every direct service cost. Attach supporting schedules for direct costs, other allowable and direct investment expenses, noting the source’s cross-reference wording.
Donations and exemptions in this edition
Approved IPC/other approved donations are shown at 2.5-times deduction; unused amounts, subject to shareholding test, carry up to five years. YA 2017 residue at end YA 2022 is not carried to YA 2023. The partial exemption from YA 2020 shows first S$10,000 at 75% and next S$190,000 at 50%, total exempt S$102,500. The notes also show start-up first S$100,000 at 75% and next S$100,000 at 50%, total S$125,000, but listing that table does not establish this investment-holding company’s eligibility.
Tax, foreign credit and old rebates
After exempt amount the template applies 17%, then foreign tax credit limited to lower Singapore tax on net foreign income or foreign tax paid. Pooling uses the lower of total Singapore tax on pooled foreign income and pooled foreign taxes. Deduct applicable CIT rebate; the source specifically lists YA 2019 20% capped S$10,000 and YA 2020 25% capped S$15,000. Preserve these as historical-year examples, not present-year rebate rates, and keep the reference links for relevant schemes.
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 ↗