Control and Management in Singapore

A company is considered tax-resident in Singapore if its control and management are exercised within the country. This typically refers to where the central management and decision-making processes take place.

Determining Factors: The factors that constitute control and management include where the board meetings are held, where strategic decisions are made, and where the directors exercise their managerial control. It's not just about the physical location of the company's operations but rather where the key management and commercial decisions are made.

Significance: Tax residency status is crucial as it can influence the company's eligibility for tax benefits, exemptions, and access to DTAs with other countries.