Matilda LTE is a company that operates electronic goods retail stores in Singapore, Australia and Hong Kong. In each country where it operates its stores, a local manager is in charge of the day-to-day management of each store.

The company was incorporated in Australia and is therefore regarded as an Australian tax resident under Australian domestic tax law.

The company has three directors, one of whom is resident for tax purposes in Australia and two of whom are resident for tax purposes in Singapore.

The board of directors meets four (4) times each year in Singapore and four (4) times each year in Australia for the purpose of exercising the company’s management decisions.

REQUIRED

(i) Advise Matilda LTE whether it is a resident of Singapore under the Singapore Income Tax Act.

(ii) Advise Matilda LTE as to its residence status under the Singapore–Australia Double Tax Agreement.

(iii) Advise Matilda LTE whether it is taxable in Singapore under the Singapore Income Tax Act and the Singapore–Australia Double Tax Agreement.

Answer rating: 100% (QA)

iYes Matilda LTE is a resident of Singapore under the Singapore Income Tax Act The company is incorporated in Australia and is therefore regarded as an Australian tax resident under Australian domestic tax law However the company has three directors one of whom is resident for tax purposes in Australia and two of whom are resident for tax purposes in Singapore The board of directors meets four 4 times each year in Singapore and four 4 times each year in Australia for the purpose of exercising the company s management decisions Given that a majority of the board of directors are resident in Singapore for tax purposes and that the board of directors exercises management decisions for the company in Singapore it is therefore reasonable to conclude that Mat ilda LTE is a resident of Singapore for tax purposes II Under the Singapore Australia Double Tax Agreement a company is regarded as a ... View the full answer