Legal names do not determine transparency
The table treats a Cayman SPC, Guernsey ICC or limited company, Luxembourg SA and SCA, and Netherlands BV as companies. German KG, Indian LLP, Japanese TK, Luxembourg SCS and SCSp, and Netherlands CV are classified as partnerships. Similar abbreviations or a foreign jurisdiction’s local tax election need not produce the same Singapore classification. Identify the exact jurisdiction and legal form before determining how foreign income is attributed.
US LLC needs its agreement
A United States LLC is classified as a company unless it can substantiate partnership classification using its LLC agreement. The exception requires evidence rather than an assumption that every LLC is transparent. The list covers selected structures and is dated; an unlisted entity needs a facts-based classification. Retain governing documents and relevant rights so that the Singapore tax treatment follows the actual structure instead of a translated entity label.
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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