IRAS updated its guidance to “relieve” conditions to apply for Singapore tax resident and fine-adjust PE definition
The Inland Revenue Authority of Singapore (“IRAS”) has updated its COVID-19 Support Measures and Tax Guidance in January 2021 to provide its view on the conditions for fulfilling tax resident status and PE related matters due to the influence of COVID-19.
The IRAS proposes to relieve the requirement of board of directors’ meetings in Singapore for application of Singapore tax resident due to the travel restrictions for the years 2021 and 2022. The relief is subject to conditions specified by the IRAS, as listed below:
The IRAS also proposes to relieve the conditions to constitute a PE in Singapore with the following
Points to Note
It is welcome that the IRAS has provided clear guidance and tax relief for determination of tax resident status and PE definition under special circumstance of COVID-19. On the contrary, in Hong Kong, taxpayers are yet to receive any clarification from the IRD on its views towards similar issues when they are approving applications of certificate of tax resident status. Given the stringent attitude of the IRD in reviewing the application in recent years, the chance of proposing similar “relief” in granting Hong Kong tax resident status remains low.