Singapore Ruling on the Treatment of Unremitted Foreign Dividend Income Used to Pay One-Tier Tax-Exempt Dividends via Offshore Accounts

The Inland Revenue Authority of Singapore has published Advance Ruling Summary No. 10/2026, which addresses whether foreign dividend income received in an offshore bank account and used directly to pay one-tier tax-exempt dividends to a shareholder's offshore account is regarded as received or deemed to be received in Singapore under Section 10(25) of the Income Tax Act 1947. This is important because if the income is not considered received in Singapore, the foreign-sourced dividends are no…