What is the Tax residence of a VCC?
VCC's Must appoint a qualifying Fund Manager to manage the VCC, however the Fund Manager can delegate fund management activity and operational duties to other parties, such as a sub-manager, that are regulated as fund managers in other jurisdictions, provided the Fund Manager of the VCC retains overall responsibility of the duties, and mitigates any conflict.
Under Singapore tax law, the tax residency of a company is determined by where the business is controlled and managed. The residency status of a company may change from year to year.
Generally, a company (including a VCC) is considered a Singapore tax resident for a particular Year of Assessment (YA) if the control and management of its business was exercised in Singapore in the preceding calendar year. Where the control and management is exercised is largely a question of fact. The location of the meetings of the VCC's board of directors, during which strategic decisions are made, will be considered as a key factor by the IRAS in determining where the control and management is exercised.