Stamp duty computation for share transfers
Stamp duty rates
Person liable to pay stamp duty
Stamp Duty Relief for Qualifying Mergers & Acquisitions (M & A) Deals:
As announced in Budget 2010 on 22 January 2010, the transfer of shares for qualifying M&A deals will be eligible for Stamp Duty relief capped at $200,000 per year. This relief is available for qualifying M&A deals executed from 1 April 2010 to 31 March 2015 (both dates inclusive).
Enhancements of Stamp Duty Relief for Qualifying M& A Deals:
As announced in Budget 2012, there are further enhancements of the stamp duty relief for qualifying M&A deals, as follows:
1) Acquisition through subsidiaries
Prior to Budget 2012 announced on 17 February 2012, the acquiring company could acquire the shares of the target company either directly or through a directly and wholly-owned subsidiary (“acquiring subsidiary”).
From 17 February 2012, the acquiring company may acquire shares of the target company through multiple tiers, instead of just one tier, of wholly-owned subsidiaries.
2) Conditions on Target Company
Prior to Budget 2012 announced on 17 February 2012, the conditions imposed on the target company could be satisfied by either the target company or by the acquiring subsidiary directly and wholly-owned by the target company.
From 17 February 2012, the conditions may be satisfied by any of the multiple tiers of wholly-owned subsidiaries of the target company.
3) Ultimate Holding Company
The acquiring company must be held by an ultimate holding company incorporated in and tax resident of Singapore. From 17 February 2012, this condition may be waived on a case-by-case basis, subject to conditions. EDB will administer this waiver.
The enhancements will take effect for qualifying M&A deals completed from 17 February 2012 to 31 March 2015 (both dates inclusive). All other existing conditions of the M&A scheme will remain the same. The full Stamp Duty on such transfers of shares will continue to be payable until details of the stamp duty relief for M&A deals are finalised. IRAS will refund Stamp Duty paid if a deal, executed on or after 1 April 2010, satisfies the finalised rules.
IRAS will release more details of the Stamp Duty relief by 30 June 2012.