IRAS has published the third edition of its e-Tax Guide clarifying GST treatment for licensed insurers transferring their businesses.
Singapore’s Inland Revenue Authority (IRAS) has issued an updated e-Tax Guide on 11 Sep 2026 (Third Edition), setting out the tax treatment for licensed insurers transferring their businesses to one another under section 117 of the Insurance Act 1966.
The guide explains how Section 34CA of the Income Tax Act 1947 (ITA) adapts the standard corporate amalgamation tax relief for such transfers, allowing them to be treated as a continuation of the existing business. It applies to schemes of transfer confirmed by court orders taking effect on or after 1 November 2021.
The third edition clarifies GST rules during the transition period. GST refunds remain payable to the transferor, which must keep its bank account open unless IRAS approves a request allowing the transferee to receive them instead. During a six-month transitional period, the transferee may claim input tax on invoices still addressed to the transferor, provided it proves payment for the purchases, takes over the related rights, notifies suppliers of the ownership change, and obtains written confirmation from the transferor that it will not also claim the tax.
Under the framework, unutilised tax losses may be carried forward to the transferee, and policy liabilities are adjusted between the transferor and transferee accordingly. A qualifying transfer between GST-registered insurers is automatically treated as a transfer of a going concern, while relief from stamp duty remains available where the relevant conditions are met.
