Singapore Income Tax Implications for MPL Group: Appraisal and Tax Saving Opportunities

Appraise the Singapore income tax implications for the MPL Group in light of the above ten (10) transactions. Where applicable, propose to the BOD how to achieve income tax saving opportunities, taking into consideration all the latest income tax changes including the proposed income tax changes as announced by the Minister for Finance in Budget 2021 on 16 February 2021. 

(a) Examine the taxing rights of Country P and Country Q on PPL’s profits from providing training services to QPL in Country Q.

(b) Assuming the plan is to set up a wholly-owned subsidiary of PPL in Country R (“subsidiary”), illustrate the tax implications for this subsidiary in Country R and PPL if the subsidiary were to declare and pay a dividend to PPL out of its after-tax profits.

(c) Assuming the tax law of Country R is the same as the tax law of Singapore, determine the income tax implications for setting up a branch in Country 

(a) From an international tax perspective, evaluate the use of Singapore as a headquarter location for the SPL Group of companies.

(b) Assuming SPL is interested in applying for tax incentives in Singapore, illustrate the two (2) relevant tax incentives SPL can consider based on the information stated above, and discuss any additional conditions SPL should be aware of.