



The Law and Practice of Singapore Income Tax
31 of the best tax minds wrote this book
Table of content and sample excerpts from the book
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• Accountants • CFOs • In House Counsel • Tax Professionals
It is our hope that successive generations of the tax community will ‘Wikipedia’ this book into the most authoritative book on Singapore taxation.
— Pok Soy Yoong
The Law and Practice of Singapore Income Tax is indeed a timely addition to the limited literature available on Singapore taxation. It will support our aspiration to be the regional centre for accountancy and taxation services.
— Moses Lee, Commissioner of
Inland Revenue Singapore
Pok is currently a non-executive director of a number of companies, both listed and unlisted.
He is currently also a member of the IRAS Board.
Prior to his consultancy work, Keat Seng was Deputy Commissioner (Business Group) of IRAS. He retired in April 2008 after having served that organisation for about 38 years. In the course of his career in IRAS, Keat Seng led various operations, including stamp duty, estate duty, taxpayer audit, collections, GST, corporate income tax, tax policy and international tax.
After retiring from the profession in 2005, he amused himself by obtaining a degree in pure mathematics from the National University of Singapore – an exercise that served to convince him that his ability to remember old tax cases greatly exceeded his limited mathematical skills.
Starting from the feasibility or opportunity assessment phase, Matthew has assisted clients from the design through to implementation/ post implementation phases, including designing or redesigning the value chain of companies to take advantage of centralised and Principal model advantages. This includes redesigning the transfer pricing model; tax/legal structure; organisational design and process flows, development of the tax and organisational transformation roadmap, implementation of the new structure via integrating key technical disciplines – direct tax; indirect tax; customs; transfer pricing; organisational design; process and controls; financial design; IT blue printing; people and change and accounting specialists.
Matthew has a Bachelor of Laws, Bachelor of Arts and Masters in Politics & Economics, and is a Barrister & Solicitor of the New Zealand High Court, and a Member of the Taxation Institute of Australia.
David was a lecturer in the National University of Singapore (NUS) for 3 years. He has a Master’s Degree in Law and a Master’s Degree in Business. He is the Senior Partner of the law firm, David Chong & Co. He is qualified as a Barrister of England, as an Advocate & Solicitor of Singapore, Malaya, Brunei, as a Solicitor in Australia and as Barrister & Solicitor of the British Virgin Islands.
David served as the Founding President of Society of Trust & Estate Practitioners (STEP) (Singapore Chapter) and was the Founding President of the Singapore Fund Administrators Association (SFAA). He is also a member of the Executive Committee of the Singapore Trustees Association (STA).
Siew Moon has over 25 years of experience in the area of taxation, and specialises in corporate and international taxation. She provides tax compliance, advisory and planning services to her clients. She advises her clients on structuring, cross-border as well as mergers and acquisitions transactions. She also assists her clients to apply for tax incentives, tax rulings and tax clarifications. She is a frequent speaker at internally and externally organised seminars.
She is married with five children.
Nicole also has significant experience in assisting clients with tax audits in Singapore and elsewhere, and has represented clients in the first bilateral Advance Pricing Agreements between Singapore and Japan, Taiwan, China, Australia and Korea. Her experience covers diverse industries such as telecommunications, technology companies, manufacturing and oil and gas. Nicole holds double degrees in Law and Accountancy from Adelaide University in Australia.
He has more than 20 years consultancy experience in dealing with various domestic and cross-border tax and business issues related to PwC’s clients in Singapore, US, Europe, India and elsewhere.
His areas of specialisation include global tax and intellectual property structuring, incentive planning, cross border M&A for multinational companies as well as local businesses.
Abhijit is an adjunct associate professor of National University of Singapore and is on the Board of Maxwell Chambers Pte Ltd (a subsidiary of Ministry of Law) which is responsible for promoting Singapore as an international arbitration centre. He is also a member of Tax Advisory Committee of Ministry of Finance and is involved in advising on fiscal policy matters.
Abhijit authored a number of articles on tax and law matters for various journals and publications and is regularly invited for media interviews and public presentations.
Abhijit is a fellow member of Institute of Chartered Accountants of India and is also an Accredited Tax Advisor (Income Tax) of SIATP.
His working career began in public practice with PricewaterhouseCoopers in London and later with KPMG in Hong Kong after which he moved to industry with Procter & Gamble. He has also spent 2 years with a branch of the United Nations Security Council known as the United Nations Compensation Commission, advising Commissioners on the verification and valuation of war reparation claims filed against Iraq after the first Gulf War. He returned to Procter & Gamble after his stint at the UN, and finally left Procter & Gamble as Associate Director for the ASEAN/ Australasia/India region to pursue a career in academia. His career to date has taken him around the world from London to Hong Kong, to Kobe, to Geneva, to Singapore, to Cincinnati, Ohio and back again to Singapore.
He is currently the Head of Programme for the Master of Taxation programme at SIM University.
Darren has a keen interest in international taxation, and in particular, in the field of transfer pricing and the tax efficient supply-change structuring. He has a keener in interest in education and training, and is always looking for ways to inspire people to understand that tax is not boring!
With KPMG, Alan has spearheaded the firm’s banking initiatives in the area of Financial Sector Incentive (FSI) work, making representations to the Monetary Authority of Singapore (MAS) on potential enhancements to the scheme based on industry feedback. Separately, to assist banking clients on their withholding tax compliance issues, Alan has led a taskforce to liaise with and attend to audit queries raised by the field audit team of the Inland Revenue Authority of Singapore (IRAS). Alan is also very active in the Islamic Finance space and advised on several Islamic debt securities (Sukuk) issuances.
Alan’s current forte lies in the area of advising on fund structures, structured finance transactions and hybrid instruments. He is an Accredited Tax Adviser with the Singapore Institute of Accredited Tax Professionals (SIATP) and Non-Practising Member of the Institute of Certified Public Accountants (ICPAS).
Paul has written widely on the taxation of financial instruments and financial institutions, ranging from taxation of derivatives and permanent establishments to transfer pricing. He has also authored a chapter entitled ‘Tax Legislation and Issues in Islamic Finance’ in Theory and Practice of Islamic Finance (Singapore: Saw Centre for Financial Studies, 2008). He is the co-editor of BCM Tax, a PwC publication on Asia Pacifi c banking and capital markets tax issues, and a member of the editorial board of Derivatives & Financial Instruments, a publication by the International Bureau of Fiscal Documentation.
Paul graduated from Nanyang Technological University of Singapore with an honours degree in accountancy. He also holds a master degree in taxation law from University of Sydney, specialising in international tax.
David heads the insurance taxation practice in KPMG Singapore and serves as the tax engagement partner for compliance and advisory work for a number of global insurance clients. He works with clients across a broad spectrum of the insurance industry including general, life, composite, captive, reinsurance and direct insurance. His insurance taxation experience includes mergers & acquisitions, demergers and divestments, inbound and outbound investments, incentive advice and applications, due diligence, portfolio transfers, tax compliance and insurance tax advisory engagements in general.
He is an Honorary Member of the Singapore Reinsurance Association finance sub-committee that looks at accounting and tax issues on behalf of reinsurers. He is also a member of the KPMG Global Insurance Tax Network. His other appointments within the Singapore tax practice include Head of Corporate Tax, Technical Resource and Risk Management. He had also served as the Head for Mergers & Acquisitions and Supply Chain within the tax practice.
Kwong Wing is the Lecturer in Revenue Practice on the Singapore Bar course.
He is the General Editor of ‘Income Tax’ and coauthor of ‘Stamp Duties’ in the standard reference work, Halsbury’s Laws of Singapore. Kwong Wing is the National Reporter for Singapore for the Section of Taxation of the American Bar Association. And he is a member of the Law Society’s corporate practice committee reviewing tax legislation.
He has appeared as Counsel in a number of notable cases before the Income Tax Board of Review, the Valuation Review Board, the High Court and the Court of Appeal in relation to tax appeals. Since leaving IRAS in 2004, he has been in legal practice specialising in tax.
Yew Kwong holds professional qualifi cations in law and real estate valuation. He received a Colombo Plan Scholarship to study at the University of Auckland where he obtained a Diploma in Urban Valuation and a Singapore Government scholarship to study at the University of Reading where he obtained a Master of Science degree in Urban Land Appraisal. Yew Kwong has authored and co-authored a number of books on tax, stamp duties and development charge. He is presently Honorary Tax Advisor to the Real Estate Developers’ Association of Singapore and an Adjunct Associate Professor in the School of Real Estate at the National University of Singapore. He is also an Accredited Tax Advisor (Income Tax) at the Singapore Institute of Accredited Tax Professionals (SIATP).
Yew Kwong is recognised as a ‘Leading Individual’ by The Asia Pacifi c Legal 500 since 2006 and listed as one of the ‘Hot 100’ lawyers of 2006 by Asian Legal Business. He is ranked as a ‘recommended tax litigator and advisor’ by PLC Which Lawyer – Tax, 2008.
Currently, Cher Hui is a Senior Teaching Fellow at the Nanyang Business School (NBS), Nanyang Technological University. She teaches ‘Principles of Taxation’, a core paper for the Bachelor of Accountancy Programme and has co-taught ‘Advanced Taxation’, an elective paper.
She has been engaged as a tax adviser for many initial public offerings of real estate investment trusts and is a core member of the asset management tax team in Ernst & Young. She has also assisted many clients in obtaining tax rulings and tax incentives.
Prior to joining Ernst & Young in May 2000, Gek Khim was an Assistant Director with the Interpretations and Treaties Branch of the Inland Revenue Authority of Singapore. She was then heavily involved in the formulation of corporate tax policies including tax rulings, drafting of tax legislations and tax treaties.
She is a regular speaker at Deloitte Singapore and South East Asia seminars and GES conferences overseas. She has also co-authored the expatriate management and administrative guide with CCH.
He has represented IRAS in civil and criminal court proceedings in the various boards of review and the Supreme Court.
Prior to his consultancy work, Keat Seng was Deputy Commissioner (Business Group) of IRAS. He retired in April 2008 after having served that organisation for about 38 years. In the course of his career in IRAS, Keat Seng led various operations, including stamp duty, estate duty, taxpayer audit, collections, GST, corporate income tax, tax policy and international tax.
Particular areas of technical specialty include loan pricing and guarantee fee analysis, advanced economic analysis within a transfer pricing context, intellectual property valuations and all aspects of VCT analysis for fully transformational reconstructions through to initial feasibility studies.
He has designed and implemented a number of applications of economic theory specifi cally for transfer pricing and VCT solutions/projects.
He is currently the Assistant Commissioner for Investigation and Forensics Division and holding the dual appointment as Assistant Commissioner for Compliance Strategy and Risk Division.
Bee Tin’s practical experience includes advising on the taxation aspects of public listings, corporate mergers, acquisitions, restructuring, and crossborder business transactions. She is often involved in liaising and negotiating with the Inland Revenue Authority of Singapore (IRAS) to obtain tax rulings on specifi c transactions, and with other government agencies on tax incentives.
Prior to joining Ernst & Young in 1997, Bee Tin was a Tax Specialist with the IRAS. For more than 9 years, she was exposed to different areas of income tax work involving corporations in different industries and has acquired in-depth understanding of the IRAS’ corporate tax policies.
Bee Tin graduated from National University of Singapore with an Honours degree in Accountancy. She is currently a member of the Institute of Certifi ed Public Accountants of Singapore (ICPAS), and an Accredited Tax Advisor with the Singapore Institute of Accredited Tax Professionals (SIATP).
Pok is currently a non-executive director of a number of companies, both listed and unlisted.
He is currently also a member of the IRAS Board.
He had served on the Income Tax Board of Review for over a decade. Currently, he is a member of the Goods and Services Tax Board of Review and Valuation Review Board. He is a tax consultant with Rajah & Tann LLP and an examiner with the Chartered Institute of Taxation in London. He is also a member of the OECD Steering Committee on International Network of Tax Researchers. He has held several visiting positions in universities including Harvard, New York University and Kyushu.
He has delivered papers in many international conferences and published articles in refereed journals and chapters in books. He is the Editor of 2 books: ‘Recent Developments in Financial Regulation and Capital Markets’ (2003) and ‘Excise Taxation in Asia’ (2007).
As a partner in the firm’s Financial Services section of Tax, he heads up the Fund Management and Real Estate division there. He is regularly involved in helping clients structure their venture capital, private equity and real estate fund projects, and works closely with the firm’s Mergers and Acquisitions, and Banking and Capital Markets teams in this regard. In this context he is a member of the firm’s Global Real Estate Tax Team. He also assists hedge fund start-ups with their structure and approach, as well as clients in bringing REITS to market. Apart from this, he also leads the Tax training and technical department for the firm.
David spent his formative years with PwC London, initially in audit before making a move to the tax department in 1983. He then spent two years with the firm in Melbourne, Australia before migrating to Singapore in 1991. He is a member of the Institute of Chartered Accountants in England and Wales as well as the Institute of Certifi ed Public Accountants of Singapore.
While at IRAS, he was the Tax Director of the Tax Policy & International Tax Division where he served as Competent Authority of Singapore, and was responsible for negotiating and concluding tax treaties, transfer pricing discussions and Advance Pricing Arrangements with overseas tax authorites. He was vitally involved in developing the Singapore transfer pricing guidelines that were issued in 2006, and he also had substantial experience in dealing with complex corporate tax issues, issuing advanced tax rulings and IRAS tax circulars.
Jee Chang now serves major MNCs across a wide range of industries and has substantial experience in advising on international tax and transfer pricing issues.
He graduated with a Bachelor of Accountancy from the Nanyang Technological University and a Master of Business Administration from INSEAD. He is a regular speaker at seminars and teaches at the Singapore Tax Academy.
Kay Kheng holds degrees in law, accountancy and taxation, including a Master of Taxation from the University of New South Wales. He has been in private practice since his admission to the Singapore Bar in 1990, save for a stint as a Legal Offi cer with the Inland Revenue Authority of Singapore in 1993/94. He is also a Fellow of CPA Australia, the Taxation Institute of Australia and the Singapore Institute of Arbitrators, and an Accredited Tax Advisor (Income Tax) at the Singapore Institute of Accredited Tax Professionals (SIATP). He is also currently a member of the Accounting Standards Council.
He is a continuing contributor to the tax chapter for the Singapore Academy of Law Annual Review of Singapore Cases since 2005. More recently, he co-authored the book Stamp Duties Act – A Commentary (LexisNexis, 2010) with Leung Yew Kwong.
Kay Kheng has been recognised as one of the leading 250 tax lawyers in the world by the Tax Directors Handbook (TDH250) since 2008. He is also recommended as a ‘recognised tax expert covering both advisory and contentious tax with a focus on tax planning advice within cross-border transactions’ by the PLC Which Lawyer – Tax, 2008.
Siau Yan read law at the London School of Economics and Political Science on a scholarship from IRAS and graduated with first class honours. He went on to obtain a masters degree in law from Cambridge University and a graduate diploma in Singapore law from the National University of Singapore. He has also completed the final examinations of the Association of Chartered Certifi ed Accountants and is a member of the Institute of Certifi ed Public Accountants of Singapore.
After returning to Singapore from his studies, Siau Yan joined IRAS and worked in a broad range of departments, including the Law Division, the Tax Policy and International Tax Division and the Enforcement Division. He was the Deputy Director of the Legislation branch when he left IRAS to see things from a different perspective.
In his time at both IRAS and Allen & Gledhill LLP, Siau Yan has appeared before the tax tribunals and the Singapore Courts in numerous cases, including the first GST appeal in Singapore, several income tax cases, including the first appeal against the application of the current anti-avoidance provision in Singapore, as well as property tax cases before the Valuation Review Board and the High Court.
He specialises in Financial Services Tax, with more than 20 years of experience in the areas of tax compliance, tax planning and advisory work for banks, securities companies, funds, real estate companies as well as local and multinational companies.
Hong Beng is heavily involved in advising on complex tax issues including structured transactions, merger and acquisition deals (including tax due diligence and pre-IPO restructuring), corporate restructuring, international tax planning and investment projects. He has extensive involvement in the implementation of the Financial Sector Incentive Scheme for numerous banks and also assisted clients in making representations to the relevant authorities on tax incentives and advance rulings on intricate issues.
As the current Head of Tax, Hong Beng is overall responsible for the KPMG Tax Practice including Corporate Tax, Indirect Taxes, Transfer Pricing and International Executive Services units. He is also a member of the KPMG Singapore Operations Committee and sits on the KPMG ASPAC Tax Board.
Hong Beng is also a regular speaker at tax seminars and also a contributor to the ‘Revenue and Taxation – Income Tax’ Volume of the Halsbury’s Laws of Singapore 2004. He has also contributed numerous thought leadership tax articles and commentaries on current and topical issues to both internal and external professional publications as well as the local medias such as Euromoney, CPA Singapore, Asia Pacifi c Journal of Taxation, The Business Tax, The Straits Times and Lianhe Zaobao.
Since 2009, Hong Beng has been an active member of the Taxation and Levies Committee of the Institute of Certifi ed Public Accountants of Singapore (ICPAS). He is also an Accredited Tax Advisor (Income Tax) with the Singapore Institute of Accredited Tax Professionals Limited (SIATP) and a Non-Practising Member of ICPAS.
Boon Ngee has extensive experience in servicing large multi-national corporations and publiclisted companies. Her diversifi ed portfolio of clients ranges from a broad spectrum of industries including transportation and logistics, power and energy, manufacturing and trading, infrastructure, construction and engineering, property development and management. She has been involved in a broad array of engagements, including providing tax advisory and consulting services on listing of companies, cross-border transactions, group and global restructurings, assets securitizations, mergers and acquisitions, due diligence exercises, obtaining of advance rulings from tax authorities and tax incentives applications.
Apart from speaking in numerous KPMG inhouse Tax Training courses and KPMG seminars, Boon Ngee is also a frequent speaker at external tax seminars, and participated as trainer in courses conducted by Tax Academy of Singapore.
Boon Ngee holds a degree of Bachelor of Accountancy [B.Acc.] from the National University of Singapore, and a law degree [LLB (Hons)] from University of London (External). She is a member of the Institute of Certifi ed Public Accountants of Singapore and is an Accredited Tax Advisor with Singapore Institute of Accredited Tax Professionals.
She has been admitted as a Solicitor and Barrister of the Supreme Court of New South Wales since 2005. Her working experience as a tax lawyer in Sydney includes giving advice on Australian taxation and superannuation matters and conducting tax litigation matters for the Australian Taxation Offi ce.
In addition to legal practice, Lian Chuan was also head of tax and a Deputy Director at the Financial Centre Development Department, Monetary Authority of Singapore, between 1998 to 2001.
Lian Chuan also holds a Master of Professional Accounting from the Singapore Management University.
Lian Chuan practices primarily in the areas of tax, financial services regulation, funds, general corporate & commercial and international wealth management, and seeks to add value to clients in particular by combining his expertise across these various areas of tax and legal work.
In the area of tax, he covers all areas of Singapore tax (including income tax, GST, stamp duty and property tax) but with a focus primarily on tax structuring and planning matters for corporate clients, with particular expertise in the fi nancial services sector. Lian Chuan has advised many financial institutions operating in Singapore.
Lian Chuan also advises clients on diverse financial services regulatory matters, obtaining licences such as banking licences, capital markets services licences, registered insurer licences, trust business licences, approved trustee and recognised market operator (RMO) status etc, regulatory and compliance obligations for financial institutions and cross-border provision of financial services. He also advises investment managers and advisers on exempt fund manager status.
Lian Chuan also undertakes corporate and funds work. In particular, he has worked on real estate investment trusts and private real equity, real estate and shipping funds investing throughout the region.
Lian Chuan also has expertise in trust law, wealth holding and philanthropic structures and the preparation of standard documentation and migration of structures.

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