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Singapore Advance Ruling on Whether a Company has a Taxable Presence in Singapore if Selling Locally Manufactured Goods

  • The Inland Revenue Authority of Singapore published Advance Ruling Summary No. 5/2025, determining that a company does not have a taxable presence in Singapore solely due to selling locally manufactured goods and receiving sales and marketing support from related entities in Singapore.
  • The ruling highlighted that the company lacks a fixed place of business, employees, and inventory in Singapore, with all sales contracts negotiated and concluded outside the country, and deliveries handled by third-party freight forwarders.
  • SG Co and SG Branch, while providing manufacturing and support services, do not create a taxable presence for the company since SG Branch cannot conclude contracts on behalf of the company, and the activities undertaken do not amount to a permanent establishment in Singapore.

Source Orbitax

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