On 1 December 2022, the Inland Revenue Authority of Singapore (IRAS) published an updated e-Tax Guide on tax exemption for Real estate investment trusts and qualifying offshore infrastructure project or asset. The e-Tax Guide describes the scenarios and conditions under which tax exemption may be granted to resident taxpayers.

Tax exemption is, subject to conditions, granted under section 13(12) of the ITA on:

  • Certain foreign-sourced income received in Singapore by resident companies under the scenarios specified in the e-Tax guide;
  • Certain foreign-sourced income received in Singapore by the trustees of Real Estate Investment Trusts listed on SGX (“S-REITs”), S-REITs’ wholly-owned (directly or indirectly) Singapore incorporated and resident companies, or S-REITs’ wholly-owned Singapore sub-trusts:
  • Certain foreign-sourced income received in Singapore by listed resident entities or their wholly-owned Singapore resident subsidiary companies from qualifying offshore infrastructure project/asset;
  • foreign-sourced income received in Singapore by resident taxpayers on a case-by-case basis.

The provisions of the e-Tax guide are generally effective from the year of assessment 2024.