Global Daily Tax News, Singapore Updates Guidance For Variable Capital Companies, (May 5, 2026)

The Inland Revenue Authority of Singapore (IRAS) has updated its guidance for variable capital companies.

The VCC is a corporate structure for investment funds that can be used across a wide range of fund strategies, and as an open-end or a closed-end fund. Besides the incorporation of new funds, the VCC framework also allows fund managers to redomicile existing overseas investment funds with structures comparable to that of a VCC, by transferring their registrations to Singapore as VCCs.

The third update to the guide includes the following changes:

• Paragraph 5.4 has been updated to clarify that the tax reference number of the sub-fund will be included in the Certificate of Residences (CORs) issued to an umbrella VCC in respect of the sub-fund;

• Paragraph 5.8 has been updated to include Section 92K of the ITA which does not apply to a VCC;

• The guidance has been updated to note the enactment of Section 14EB of the Income Tax Act;

• The table in paragraph 5.10 has been updated to include exemption for foreign-sourced income;

• Footnote 28 has been updated to reflect the CIT rebate and CIT rebate cash grant announced in Budget 2026 and the Ministerial Statement on the impact of Middle East Situation on Singapore announced on April 7, 2026; and

• Paragraphs 5.17 to 5.19 have been inserted on exemption for foreign-sourced income, which is applicable to sub-fund(s) of a VCC.