Singapore Advance Ruling on Withholding Tax Treatment of Discounts on the Sale of Trade Receivables

The Inland Revenue Authority of Singapore has published Advance Ruling Summary No. 6/2024 on the withholding tax treatment of discounts on the sale of trade receivables.

Advance Ruling Summary No. 6/2024

1. Subject:

a. Whether the "discount" on Company A's sale of trade receivables to banks, being non-tax resident persons, in discounting arrangements fall within the meaning of section 12(6)(a)(i) of the Income Tax Act 1947 ("ITA").

2. Relevant background and facts:

a. Company A is i…