The e-Tax Guide outlines the tax framework applicable to VCCs and is intended for individuals or entities involved in incorporating, registering, or managing a VCC.
The Inland Revenue Authority of Singapore (IRAS) has published an updated e-Tax Guide on Tax Framework for Variable Capital Companies (Third Edition) on 30 September 2025.
This e-Tax Guide explains the tax framework for variable capital companies (“VCCs”). It is relevant to you if you are seeking to incorporate or register a VCC, or if you are managing one.
VCCs incorporated under the VCC Act are treated as companies incorporated under the Companies Act 1967 for income tax purposes.
Further, regardless of whether a VCC is a non-umbrella VCC or an umbrella VCC comprising (or that will comprise) two or more sub-funds, it will be recognised as a single entity for income tax purposes, unless stated otherwise.
Following amendments in the third edition of the e-Tax Guide:
- Updated the table in paragraph 5.8 on the sections of the ITA where a VCC will not be allowed a deduction for expenses and inserted new footnote 19.
- Inserted new footnote 22 on qualifying preference shares.
- Updated footnote 28 to reflect the CIT rebate and CIT rebate cash grant announced in Budget 2025.
- Inserted new paragraphs 5.22 to 5.24 to incorporate the section 13W enhancements announced in Budget 2025.
- Inserted new paragraphs 5.30 to 5.35 to provide information on how control is determined for VCCs and their subfunds.
- Inserted a new section 8 on frequently asked questions.
- Updated the numbering of footnotes and sections.
