Tax Framework for Variable Capital Companies

This e-Tax Guide explains the tax framework for variable capital companies
(“VCCs”). It is relevant to you if you are seeking to incorporate or register a
VCC, or if you are managing one

For GST purposes, each sub-fund of an umbrella VCC is regarded as a
separate person, as a sub-fund makes independent sale and purchase
decisions based on its respective investment mandate.

Therefore, each subfund is required to assess its GST registration liability based on the value of
its taxable supplies made. If a sub-fund is GST-registered, it will account for
GST on its taxable supplies including any taxable supplies made to another
sub-fund of the same VCC.

Similarly, it can claim input tax on its taxable
purchases, subject to the existing input tax recovery and attribution rules.
2.3 The GST remission for qualifying funds is extended to qualifying VCCs.
Under the GST remission, non-GST registered qualifying non-umbrella
VCCs and sub-funds of umbrella VCCs will be able to recover GST incurred
on expenses based on a fixed recovery rate

Source: gov.sg

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