Key steps and distinctions
For disposals from 1 January 2026, eligible shares include ordinary shares and preference shares accounted for as equity by the investee, and the previous sunset date is removed. The 20% threshold refers to the total paid-up capital of ordinary and qualifying preference shares held continuously for at least twenty-four months immediately before disposal. Where the divesting entity does not meet it alone, qualifying company groups may aggregate continuously held shares. Group membership requires more than 50% beneficial ordinary-share ownership through the relationships specified, and only disposed shares held throughout the relevant period receive the group-based benefit; use FIFO for the prescribed holding assessment. Registered business trusts and variable capital companies cannot use the group basis. Check exclusions for section 26 divesting income and specified unlisted property-related investees. For post-1 June 2022 property development, the exception requires own-business trade use and no development activity in the previous sixty months; passive rental use is different. Failure to meet the certainty scheme does not automatically make gains taxable, and qualifying-looking losses are not automatically disregarded: ordinary revenue-versus-capital analysis remains necessary. The scheme applies to eligible listed or unlisted, Singapore or foreign investees subject to these conditions.
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.
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