HIGH
Lawyers
practice change
IRAS e-Tax Guide Tax Framework for Variable Capital Companies Revised
Full page →
IRAS e-Tax Guide Tax Framework for Variable Capital Companies Revised
Lawyers advising on VCC structures will need to flag to clients the obligation under paragraph 7.7 to lodge a notice with the Commissioner of Stamp Duties under section 60I or 60J of the Stamp Duties Act within 14 days where an umbrella VCC effects an intra-structure acquisition or disposal without executing a formal dutiable instrument. Non-compliance constitutes a criminal offence with a penalty of up to four times the applicable stamp duty. Advocates and solicitors holding Practising Certificates and acting in corporate or funds mandates carry advisory responsibility for identifying this obligation on each relevant VCC transaction.
Source
"the umbrella VCC must give a notice to the Commissioner of Stamp Duties within 14 days of the transaction with its sub-fund"
Para 7.7
Open source document →
Action Required
Add intra-VCC instrument-free transaction trigger to VCC transaction due diligence checklist; include s60I/s60J notice deadline (14 days) as a standing advisory item in VCC mandate engagement letters