Exchange is subject to safeguards
Singapore exchanges specified ruling information under the BEPS minimum standard with jurisdictions having an appropriate treaty or arrangement, confidentiality safeguards and reciprocal commitment. Relevant recipients include qualifying related-party jurisdictions, immediate and ultimate parent residence and, for PE rulings, head-office residence. Related-party status uses a 25% threshold in voting rights or equity value, directly or indirectly, including comparable application to partnerships and trusts. It is not publication of every ruling to all jurisdictions.
Timing changed for later rulings
Rulings issued from 1 April 2017 to before 2025 are exchanged as soon as possible and within three months after becoming available to IRAS. Those issued from 1 January 2025 are exchanged within six months of issue, defined as taxpayer acceptance. Taxpayers are not routinely informed whether, when or to whom exchange occurs. Distinguish the acceptance date from an earlier application date when assessing the relevant exchange period.
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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