Articles

Three Singapore obstetricians lost a High Court challenge over tax avoidance. They paid themselves low salaries (S$5,000–S$6,000 monthly) while taking millions in dividends and interest-free loans from personal companies. IRAS deemed the arrangement artificial, as salaries weren't market-rate and didn't reflect growing profits. The court upheld revised tax assessments, with penalties now including a 50% surcharge.

The Indian Supreme Court in Tiger Global (2026) incorrectly used anti-abuse (GAAR) standards to determine treaty residence, reversing the legal sequence. This merges distinct inquiries—residence status and benefit denial—undermining bilateral treaty certainty. The ruling transforms a fixed status into a variable one, creating instability for cross-border investment planning.