TAX Main Assignment:

Your client is planning to set up an investment company (private limited) in Singapore in mid 2018. Their funds will be invested in shares of public listed companies and also on real properties. But they are in a dilemma on whether to set up an investment holding or investment dealing company. Some of your clients friends have prompted that the tax treatment between the two are different.

However your clients intention is to minimise their tax obligations in Singapore from their business venture.

Prepare a short write up (not exceeding 1,500 words) by identifying the key differences between investment holding and investment dealing based on tax treatment and also on advising them appropriately on which will be the optimum set up that will meet your clients intention. In your discussion include the following:

1) The deductibility of expenses;

2) The application of capital allowances;

3) The restrictions of Section 10E of SITA;

4) The application of business loss if any;

5) The operations of Section 10(1)(a),10(1)(d) and 10(1)(f) 6) Your final advice on the decision to set up an investment company.