Striking the right balance · Singapore tax cases ... May 1992 April 2006 New SG branch registered June 2004 SG branch de-registered YA 2008 PwC Unabsorbed losses = $30m Profits 10

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Striking the right balancePwC Budget Seminar1 March 2013

- Updates on tax cases

Agenda

Singapore tax cases

• AVD v Comptroller of Income Tax• AVD v Comptroller of Income Tax

• AYH v Comptroller of Income Tax

• AYN Corporation v Comptroller of Income Tax

• Comptroller of Income Tax v AZP

• U Limited v Comptroller of Income Tax

• FEOL v Comptroller of Income Tax

PwC

• AQQ v Comptroller of Income Tax

• STM Pte Ltd v Comptroller of Income Tax

• AQP v Comptroller of Income Tax

2PwC Budget Seminar 2013

Agenda

Overseas tax cases

• Beneficial ownership in tax treaties• Beneficial ownership in tax treaties

• Canadian tax case

- Velcro Canada Inc v The Queen

• Swiss tax case

- Swiss Swaps I/A

PwC 3PwC Budget Seminar 2013

Singapore tax casesAVD v Comptroller of Income Tax [2011] SGITBR 3

H

Before restructuring After restructuring

1%J Ltd

B Pte Ltd

G KL

H

67% J Ltd

B Pte Ltd

G

33%

33%

33%

33%


AVD

B Pte Ltd

AVD

B Pte Ltd

100% owned unless stated otherwise

Singapore tax casesAVD v Comptroller of Income Tax

Issue

• Whether the Comptroller had properly exercised his discretion under• Whether the Comptroller had properly exercised his discretion undersection 37(16) of the Income Tax Act in not agreeing to waive theshareholders' test in section 37(12), thereby not allowing AVD tocarry forward its unabsorbed losses.

Facts

• Group restructuring involving members of the same family

• AVD had losses – requested Comptroller to waive the shareholders'

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• AVD had losses – requested Comptroller to waive the shareholders'test

• Comptroller consistently refused the application – change resultednot for commercial reasons but "for personal/private reasons“


Singapore tax casesAVD v Comptroller of Income Tax

Board of Review

• The law requires that the change must not be for the purpose of• The law requires that the change must not be for the purpose ofderiving any tax benefit or obtaining any tax advantage

• Restructuring was not tax motivated – not challenged by Comptroller

• Board found Comptroller should have granted waiver

• Consistent refusal on the basis that facts did not fall withincircumstances stated in the IRAS circular and that the change was forpersonal reasons – unlawful fetter on the Comptroller’s discretion

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personal reasons – unlawful fetter on the Comptroller’s discretion

• Doubtful whether the Comptroller genuinely considered AVD’s case


Singapore tax casesAYH v Comptroller of Income Tax [2011] SGITBR 4

December 1995 1998

Constructionof mallcompleted andfully leased out

Adjacent landplots

acquired

Buildingof newwing

November 1997 December 1999

TOPissuedfor newwing


Issue: Whether the acquisition of new plots of land and construction ofan additional wing to an existing shopping mall could be regarded asbeing part of the same investment as the existing mall for the purposes ofinterest deduction under section 10E(1) and section 14.

Singapore tax casesAYH v Comptroller of Income Tax

Facts

• AYH is a section 10E company• AYH is a section 10E company

• Original site – shopping mall was built

• New land plots acquired to build an extension to the existing mall

• Post-acquisition of new land plots, gross plot ratio of the original sitewas increased to match that of new plots

• Lease term of new land plots was granted to coincide with the expirydate of the lease for the original plot

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date of the lease for the original plot

• Acquisition of new land plots and construction of new wing financedby loans

• Interest expenses incurred in YAs 1998 to 2000 before TOP wasissued


Singapore tax casesAYH v Comptroller of Income Tax

Board of Review

• AYH was unable to demonstrate that the original intention when it• AYH was unable to demonstrate that the original intention when ittendered for the original plot was to invest in an integrated mall,spanning the new land plots, within a reasonable time frame

• Uncertainty in the bidding process for the new land plots – AYH wasprepared to pay a premium to secure the plots given seven otherbidders

• New land plots were a separate investment – interest costs notdeductible

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deductible


Singapore tax casesAYN Corporation v Comptroller of Income Tax [2012]SGITBR 1

SGbranchregistered

May 1992 April 2006

New SGbranchregistered

June 2004

SGbranchde-registered

YA 2008

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ProfitsUnabsorbed losses = $30m


Issue: Whether the losses incurred by an old (de-registered) branch of aforeign company can be utilised against the profits earned by the newbranch of that company.

Singapore tax casesAYN Corporation v Comptroller of Income Tax

Comptroller’s arguments

• A branch is treated as a distinct and separate entity from the• A branch is treated as a distinct and separate entity from theenterprise of which it is a part for income tax purposes

• Singapore branch’s profits are ring-fenced – losses to be disregardedonce branch operations cease

Taxpayer’s arguments

• A branch is an extension of its head office – not a separate entity

• It is the foreign company that carries on the business, not the branch

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• It is the foreign company that carries on the business, not the branch

• Section 37(3)(a) of the Income Tax Act – loss incurred by a “person” refers to the legal entity, not the branch


Singapore tax casesAYN Corporation v Comptroller of Income TaxBoard of Review

• “Person” in section 37 refers to a legal entity who is a taxpayer

• Whether business in Singapore was carried on by the old or new• Whether business in Singapore was carried on by the old or newbranch, it was AYN Corporation that carried on the business – abranch has no separate personality

• Article 7(2) of the tax treaty treats a PE in Singapore as if it were adistinct and separate enterprise for the purposes of profit attribution– not concerned with how Singapore deals with the profits sodetermined. It does not modify section 37.

Singapore-Japan tax treaty


Singapore-Japan tax treatyArticle 7(1): The profits of an enterprise of a Contracting State shall be taxable only in that Contracting Stateunless the enterprise carries on business in the other Contracting State through a permanent establishmentsituated therein. If the enterprise carries on business as aforesaid, the profits of the enterprise may be taxed in thatother Contracting State but only so much of them as is attributable to that permanent establishment.Article 7(2): Subject to the provisions of paragraph 3, where an enterprise of a Contracting State carries onbusiness in the other Contracting State through a permanent establishment situated therein, there shall in eachContracting State be attributed to that permanent establishment the profits which it might be expected to make if itwere a distinct and separate enterprise engaged in the same or similar activities under the same or similarconditions and dealing wholly independently with the enterprise of which it is a permanent establishment.

Singapore tax casesComptroller of Income Tax v AZP [2012] SGHC 112

Issue

• Whether information requested by the Indian tax authorities (throughthe Comptroller) was ‘foreseeably relevant’ for carrying out thethe Comptroller) was ‘foreseeably relevant’ for carrying out theprovisions of the Singapore-India tax treaty or the administration ofIndia’s tax law, under Article 28(1) of that treaty.

Facts

• Application by the Comptroller under section 105J for an order requiringAZP, a bank in Singapore, to produce records and information relating totwo bank accounts, from 1 January 2008, held with AZP

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• Account 1 was held by Company X and Account 2 was held by CompanyY

• Indian tax authorities had seized certain documents from an Indiannational – it was alleged that the two accounts held with AZP wereassociated with that Indian national


Singapore tax casesComptroller of Income Tax v AZP

High Court

• Application was dismissed• Application was dismissed

• Companies X and Y were not Indian-incorporated entities – notunder any investigation by the Indian tax authorities

• No evidence from the Indian tax authorities of any transactionbetween the Indian national and either company on or after 1January 2008 (effective date of the exchange of information clause)

• Only evidence was certain unsigned transfer instructions issued

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• Only evidence was certain unsigned transfer instructions issuedbefore 2008

• Obiter dicta – no evidence that making the order for the Indian taxauthorities to gain access to the information, was justified undersection 105J


Singapore tax casesU Limited v Comptroller of Income Tax [2012] SGITBR 2

Issue

• Whether gains arising from the disposal of shares by U Limited were• Whether gains arising from the disposal of shares by U Limited weretaxable under the Income Tax Act.

Facts

• U Limited was a general insurer and was part of the O group

• U Limited held certain shares in ABC Bank, Q Ltd and XY Ltd. ABCBank was later taken over by DEF Bank and U Limited sold all sharesto DEF Bank

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to DEF Bank

• Shares in ABC Bank were acquired directly from ABC Bank throughrights issues and bonus issues over a period of 40 years. Shares of QLtd and XY Ltd were held for 20 and 27 years respectively


Singapore tax casesU Limited v Comptroller of Income Tax


• Shares were acquired to preserve the corporate structure of the O• Shares were acquired to preserve the corporate structure of the OGroup and to promote the long-term strategic interest of itself andthe O Group

• Shares formed part of the core stock of the O Group

• Gains were therefore capital in nature


• “Mini regime” for taxation of insurance companies within section 26

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• “Mini regime” for taxation of insurance companies within section 26– any profits or gains realised from sale of investments are taxable

• Badges of trade were not relevant in this context


Singapore tax casesU Limited v Comptroller of Income Tax

Board of Review

• No separate taxation regime for insurance companies – insurance• No separate taxation regime for insurance companies – insurancecompanies can hold shares as capital assets

• Charging section, i.e. section 10, continues to be relevant – onlywhere gains or profits from the sale of shares amount to trading gainswould they be liable to tax

• Section 26(4) is concerned with ascertaining the gains and profitsderived by an insurance company accorded a concessionary tax rateor tax exemption

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or tax exemption

• The shares were core stocks held for long-term strategic purposes –gains from disposal of shares are capital in nature and hence nottaxable


Singapore tax casesFEOL v Comptroller of Income Tax (2013) MSTC 50-011

Facts

• Taxpayer issued two five-year bonds: ‘1995’ bonds and ‘1996’ bonds• Taxpayer issued two five-year bonds: ‘1995’ bonds and ‘1996’ bonds

1995 secured bonds 1996 unsecuredbonds

Principal amount $150m $165m

Interest payable 5.625% p.a. 5.75% p.a.

Discount to issued price 0.4305% - $645,750 7.0803% - $11.68m

Redemption premium 1.5% of the principal - $2.25m NA


Utilisation (a) Financing hotel renovationworks

(b) Re-financing of existingborrowings

(c) Working capital

Working capital

Singapore tax casesFEOL v Comptroller of Income Tax

Facts

• The Comptroller allowed a deduction for interest expense incurred• The Comptroller allowed a deduction for interest expense incurredfor funds employed on hotel refurbishment

• Balance of proceeds raised treated as a mixed pool of funds – interestadjustment using the Total Assets Method

• Comptroller disallowed deductions for the discounts and redemptionpremium incurred

Issue

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Issue

• Whether the discounts given and the redemption premium paid aredeductible.


Singapore tax casesFEOL v Comptroller of Income Tax

Board of Review

• Discount

- A discount is given on the face value of the bonds – no outwardpayment by the Taxpayer

- Discounts are therefore not outgoings and expenses incurred bythe Taxpayer

• Redemption premium

- One-time payment upon redemption of the 1995 bonds – morelikely to be a capital expenditure

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likely to be a capital expenditure

• Both are not ‘interest’ – therefore not deductible under section14(1)(a)

• Interest on mixed pool of funds (less refurbishment expenses) –deduction disallowed under section 15(1)(c)


Singapore tax casesAQQ v Comptroller of Income Tax [2012] SGHC 249

Facts

• Group corporate restructuring with external financing taken• Group corporate restructuring with external financing taken

• Complicated fund flows involving external bank, N Bank

• Interest deduction claimed against franked dividends – resulted intax repayable of $13.6m for AQQ


Singapore tax casesAQQ v Comptroller of Income Tax

Group structure

B (M)

C (M) D

F

G

50%

50%

50%

50%

AQQ

B (M)

JF GD

C (M)


G

J50% 50%

Before reorganisation After reorganisation

100% owned unless otherwise indicated.M = Malaysian company


AQQ N Singapore1. N Singapore subscribes for $225m of the Notes

Fund flows

AQQ N Singapore

D

B (M)

C (M)N Mauritius

1. N Singapore subscribes for $225m of the Notes– 10-year tenure @ 8.85% per annum.

$75m

$75m

$75m

2. AQQbuysshares inD, F, G andJ for$225m.

$75m

$75m

$150m

3. D and Beach extenda $75minterest-freeloan to C. Chas $225m.

4. Sale and purchaseof $205m of thePrincipal Notes (and$20m of thePrincipal Notesunder a forwardagreement).

6. $20m deposit is placed withN Singapore. The same isthen withdrawn after 2months.


C (M)N Mauritius$75m $150m

5. Sale and purchase of $205mof the Principal Notes (and$20m of the Principal Notesunder a forward agreement).

7. C acquires theremaining $20m of thePrincipal Notes.


Section 33

(1) Where the Comptroller is satisfied that the purpose or effect of any arrangement is directly orindirectly –indirectly –

(a) to alter the incidence of any tax which is payable by or which would otherwise have been payableby any person;

(b) to relieve any person from any liability to pay tax or to make a return under this Act; or

(c) to reduce or avoid any liability imposed or which would otherwise have been imposed on anyperson by this Act,

the Comptroller may, without prejudice to such validity as it may have in any other respect or forany other purpose, disregard or vary the arrangement and make such adjustments as he considersappropriate, including the computation or recomputation of gains or profits, or the imposition of

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appropriate, including the computation or recomputation of gains or profits, or the imposition ofliability to tax, so as to counteract any tax advantage obtained or obtainable by that person from orunder that arrangement.

(3) This section shall not apply to –

(a) any arrangement made or entered into before 29th January 1988; or

(b) any arrangement carried out for bona fide commercial reasons and had not as one of its mainpurposes the avoidance or reduction of tax.



Issue

• Did the financing arrangement constitute a tax avoidance scheme• Did the financing arrangement constitute a tax avoidance schemewithin the meaning of section 33 of the Income Tax Act?

Board of Review

• Concluded arrangement was a tax avoidance scheme within section33



High Court

• Application of section 33• Application of section 33

- First, determine if the arrangement falls within section 33(1) –objective approach

- If it does, ask whether statutory exceptions in section 33(3) apply –subjective test

- If neither statutory exception applies, Comptroller may exercisepowers under section 33(1)

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powers under section 33(1)

• Transactions split into two parts:

- Group restructuring for group relief purposes

- Financing arrangement



High Court

• Group restructuring for group relief accepted as genuine• Group restructuring for group relief accepted as genuine

• Financing arrangement was a tax avoidance scheme

• Interest withholding tax liability was also avoided by C

• Other features of arrangement supporting finding

- AQQ “grossly overpaid” for the subsidiaries.

- Interest rate for the notes – no explanation for arriving at the8.85% rate

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8.85% rate

- Inter-company loan by D and B – why C and N Bank had to beinvolved

- N Bank did not take on actual credit risk – funds flowed back tothe group on the same day



High Court

• But Comptroller counteracted the tax advantage obtained by AQQ• But Comptroller counteracted the tax advantage obtained by AQQincorrectly

- Comptroller should not have disregarded dividend income

- Withholding tax should be collected on the interest on the $75mloan

- Interest deduction attributable to the $75m loan made by C shouldbe given

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be given

• Notices of additional assessment ought to be discharged – they wereultra vires and void

• Appeal by AQQ was allowed

• The IRAS is understood to have appealed; AQQ has cross-appealed


Singapore tax casesSTM Pte Ltd v Comptroller of Income Tax [2013] MSTC50-013

IssueIssue

• Whether an upfront payment made to secure a 3G licence and 3Gspectrum rights is tax deductible.

Facts

• Taxpayer is a mobile telecommunications operator

• It made a lump sum payment to IDA for the 3G spectrum rights andfor 3G Facilities-based Operator (FBO) licence to provide 3G mobile

PwC

for 3G Facilities-based Operator (FBO) licence to provide 3G mobiletelecommunication services

• A deduction was claimed and it was disallowed by the Comptroller


Singapore tax casesSTM Pte Ltd v Comptroller of Income Tax


• Most services that could be provided on the 3G network were already• Most services that could be provided on the 3G network were alreadybeing provided or could be provided on the 2G network but at aslower speed

• Taxpayer needed 3G FBO licence to build a 3G network and provide3G services

• 3G services could be provided on 2G network by paying annuallicence fees based on turnover of 3G services (with amendments to

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licence fees based on turnover of 3G services (with amendments to3G FBO licence)

• Lump-sum 3G payment was calculated with reference to the annuallicence fee for the provision of existing 2G services

• Acquisition of 3G spectrum rights and licence was meant to protectcustomer base – preservation of market share




• Taxpayer obtained an enduring benefit – 3G licence allowed theTaxpayer to lawfully build 3G systems and provide 3G services

• 3G FBO license and spectrum rights strengthened the Taxpayer’sprofit-making structure

• 3G FBO licence permitted Taxpayer to offer certain new services

• Payment ensured certainty for the right to use additional spectrumcapacity for 20 years

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capacity for 20 years



Board of Review

• Lump-sum payment secured an enduring benefit of a capital nature• Lump-sum payment secured an enduring benefit of a capital nature

- licence allowed Taxpayer to install 3G systems and provide 3Gservices

- taxpayer was conferred 20-year right to use the spectrum

- other than to protect its existing customer base, payment alsoenabled Taxpayer to enlarge that base and increase revenue fromproviding wider services

PwC

• One-time payment for a 20-year right is more likely to be capital innature

• No requirement for Taxpayer to have acquired asset in a proprietarysense for the payment to be considered capital in nature


Singapore tax casesAQP v Comptroller of Income Tax [2013] SGCA 3

Issue

• Whether losses arising from the ex-managing director’s• Whether losses arising from the ex-managing director’smisappropriation of funds are deductible under section 14(1) of theIncome Tax Act.

Facts

• C, AQP’s managing director, was dismissed in December 1999 formisappropriating company funds

• AQP made a provision for doubtful debts of $12.3m in its statutory

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accounts for financial year ended 31 December 1999 – no taxdeduction was claimed in its YA 2000 tax return

• In 2005, AQP lodged an “error or mistake” claim under section 93Aof the Income Tax Act

• Comptroller denied the deduction


Singapore tax casesAQP v Comptroller of Income Tax

Board of Review and High Court

• Reviewed defalcation cases in various common law jurisdictions

• Loss of AQP is not deductible – C possessed an overriding power orcontrol in the company and the misuse was committed in exercisingsuch power or control

• Passing remark on “error or mistake” claim – not restricted to mereignorance; covers genuine mistakes of law

Court of Appeal

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Court of Appeal

• The first question is whether an employee has overriding power orcontrol over the organisation and its activities – substance over form



Court of Appeal

• If so, the court must enquire whether there is a sufficient system of• If so, the court must enquire whether there is a sufficient system ofchecks and balances in place to prevent defalcations of its funds bysuch employees

• If there is no sufficient system of checks and balances, the nexus for adeduction claim is broken

• If there are checks and balances and misappropriation occurs in spiteof that, a deduction should be allowed

PwC

• Where an employee had no overriding power or control and thereforeit would be impractical to institute checks and balances to preventdefalcations, a deduction should be allowed



Court of Appeal

• Whether there is a sufficient set of checks and balances – substance• Whether there is a sufficient set of checks and balances – substanceover form

• Onus of proof is on taxpayer

• Case is remitted to the Board of Review – fact-finding on two points

- Whether C was in a position of overriding power or control for thepurpose of the present civil proceedings;

- Whether a sufficient system of checks and balances was in place

PwC

- Whether a sufficient system of checks and balances was in place

• No comment on section 93A observations of lower tribunal


Overseas tax casesBeneficial ownership in tax treaties

What does it mean?

• First introduced in the 1977 version of the OECD Model Convention• First introduced in the 1977 version of the OECD Model Convention

• Concern that lower treaty rates in Articles 10 to 12 (i.e. dividend,interest and royalty) would apply to an agent or nominee with legalright to the income

“(Standard) Article 10 – Dividends1. Dividends paid by a company which is a resident of a Contracting State

to a resident of the other Contracting State may be taxed in that otherState.


State.2. However, such dividends may also be taxed in the Contracting State of

which the company paying the dividends is a resident and according tothe laws of that State, but if the beneficial owner of the dividends isa resident of the other Contracting State, the tax so charged shall notexceed...”

Overseas tax casesBeneficial ownership in tax treaties

What does it mean?

• Original reason for beneficial ownership concept remove• Original reason for beneficial ownership concept removecustodians with legal entitlement to income from gaining access totreaty benefits

• OECD commentary regarding beneficial ownership concept wasmodified in 1992 and 2003

• Beneficial ownership concept is increasingly used as an anti-treatyshopping provision by tax authorities globally

PwC

• Discussion draft entitled “Clarification of the Meaning of ‘BeneficialOwner’ in the OECD Model Tax Convention” published in April 2011.

• Revised discussion draft released in October 2012


Canadian tax case

Velcro Canada Inc v The Queen

Velcro

VIBVVIBV

VIBV(Dutch

resident)

VelcroCanada

(Canadianresident)

LicenceagreementUp till 26 October 1995

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On 26 October 1995


VIBV(Netherlands

Antillesresident)

VIBV(Dutch

resident)

Change intax

residence

Canadian tax case


VIBVVHBVAssignment

VHBV(Dutch

VIBV(Netherlands

VelcroCanada

(NetherlandsAntilles

resident)

VHBV(Dutch

resident)

Assignment

On 27 October 1995

1996 – 2004

Paysroyalties

Paysroyalties


(Dutchresident)

(NetherlandsAntilles

resident)

Canada(Canadianresident)

1996 – 2004royalties royalties

Canada-Netherlandstreaty WHT of 25%

if not thebeneficialowner

Canadian tax case


VHBVVIBVVelcro Pays Pays

VHBV(Dutch

resident)

VIBV(Netherlands

Antillesresident)

VelcroCanada

(Canadianresident)

Paysroyalties

Paysroyalties

Canada-Netherlandstax treaty WHT of 25%

if not thebeneficialowner


Issue: Whether VHBV is the beneficial owner of the royalty incomeunder the Canada-Netherlands tax treaty?

Canadian tax caseVelcro Canada Inc v The Queen

Tax Court of Canada

• Four elements of beneficial ownership: possession, use, risk and• Four elements of beneficial ownership: possession, use, risk andcontrol

• Funds deposited into VHBV’s accounts and available for use as VHBVsaw fit

• Bank and financial statements showed commingling of moneys andunrestricted flow of funds from and between VHBV’s accounts

• VHBV did not seek instructions on application of funds

PwC

• VHBV did not seek instructions on application of funds

• Royalties did not go in and come out in an automated fashion


Canadian tax caseVelcro Canada Inc v The Queen

Tax Court of Canada

• VHBV assumed some risks in relation to the royalty• VHBV assumed some risks in relation to the royalty

- VIBV had no priority as a creditor

- VHBV not indemnified in any way to reduce the risks and exposures

- VHBV had currency risks – royalties received in Canadian fundsand converted to US funds or Dutch funds

• No predetermined flow of funds, simply a contractual obligation to paya royalty to VIBV

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a royalty to VIBV

• No evidence that VHBV acted as a nominee or conduit – VHBV hadcomplete discretion in the use of funds and acted on its own account atall times


Swiss tax case

Swiss Swaps I/A

Danish bank

Counter-parties (in the

TotalreturnHedge

exposure Danish bank US, the UK,Germany

France, etc)

returnswapsfor Swissequities

Swiss dividends – refundof WHT under theSwitzerland-Denmark taxtreaty

exposure– boughtfromdifferentthirdparties

Swissequities


Issue: Whether the Danish bank is the beneficial owner of the dividendsunder the Switzerland-Denmark tax treaty and is therefore entitled, under thetreaty, to a full refund of the 35% Swiss withholding tax withheld previously.

Swiss tax caseSwiss Swaps I/A

Swiss Federal Administrative Tribunal

• Yes, the Danish bank is the beneficial owner• Yes, the Danish bank is the beneficial owner

• A beneficial owner is a person who has the authority to decide howdividend proceeds are to be utilised

• Danish bank was not required to hedge its risk position under thetotal return swap – it was able to use the dividend proceeds for otherpurposes

• It was obliged to pay on an amount equal to the dividend proceeds

PwC

• It was obliged to pay on an amount equal to the dividend proceedseven if it had not received any dividend income


Thank you

Shantini Ramachandra Tax Director +65 6236 3823 [email protected]

This presentation has been prepared by PwC for general guidance on matters of interest only, and is not intended to provide specific advice onany matter, nor is it intended to be comprehensive. No representation or warranty (express or implied) is given as to the accuracy orcompleteness of the information contained in this presentation, and, to the extent permitted by law, PwC firms do not accept or assume anyliability, responsibility or duty of care for any consequences of you or anyone else acting, or refraining to act, in reliance on the informationcontained in this presentation or for any decision based on it. If specific advice is required, or if you wish to receive further information on anymatters referred to in this presentation, please speak with your usual contact at PwC or those listed in this presentation.

© 2013 PricewaterhouseCoopers Services LLP. "PricewaterhouseCoopers" and "PwC" refer to the network of member firms ofPricewaterhouseCoopers International Limited ("PwCIL"). Each member firm is a separate legal entity and does not act as agent of PwCIL orany other member firm. PwCIL does not provide any services to clients. PwCIL is not responsible or liable for the acts or omissions of any of itsmember firms nor can it control the exercise of their professional judgment or bind them in any way. No member firm is responsible or liable forthe acts or omissions of any other member firm nor can it control the exercise of another member firm's professional judgment or bind anothermember firm or PwCIL in any way.

Documents

Striking the right balance · Singapore tax cases ... May 1992 April 2006 New SG branch registered June 2004 SG branch de-registered YA 2008 PwC Unabsorbed losses = $30m Profits 10