Singapore Advance Ruling on Economic Substance Requirements for a Pure Equity-Holding Entity

The Inland Revenue Authority of Singapore has published Advance Ruling Summary No. 7/2025 on the economic substance requirements for a pure equity-holding entity (PEHE), which when met, provide for an exemption from tax on foreign-sourced disposal gains.

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Advance Ruling Summary No. 7/2025

1. Subject:

Whether the gains from the sale of shares in Company B by Company A to third-party buyers will be regarded as not subject to tax under section 10L of the Income Tax Act 1947 ("ITA"), on…