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IRAS e-Tax Guide Tax Framework for Variable Capital Companies Revised
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IRAS e-Tax Guide Tax Framework for Variable Capital Companies Revised
Paragraph 5.4 of this IRAS e-Tax Guide clarifies that Certificates of Residence for sub-funds of umbrella VCCs are issued in the umbrella VCC's name with the sub-fund's tax reference number included, as sub-funds are not legal persons capable of independent COR issuance. Tax agents filing COR applications for umbrella VCC clients via myTax Portal will need to identify each sub-fund correctly within the application — a maximum of five sub-funds per submission — to support double taxation relief claims under Singapore's treaty network.
Source
"the tax reference number of the sub-fund will be included in the CORs issued to an umbrella VCC in respect of the sub-fund"
Para 5.4
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Action Required
Update COR application filing procedure for umbrella VCC clients to include sub-fund tax reference number confirmation; document five-sub-fund-per-application limit in client service checklist