1 Previously, bodies of persons were subject to a different graduated rate of tax from individuals. With effect from YA 2009, bodies of persons are subject to the same flat rate of tax as companies.
2 For YA 2008 and subsequent YAs, varying degrees of partial exemption of income apply to the first $300,000 of chargeable income of a company.
3 Peter G. Whiteman, Whiteman on Income Tax (4th Rev Ed) (
4 The policy rationale behind the capital allowance regime is to promote capital investment in certain specified sectors only.
5 Similarities between the Singapore provision and these two sections can be found in Tan Wee Liang, Tax Avoidance and Section 33 of the Income Tax Act, (1989) 31 Mal. L.R. 78 at pp. 83 – 85.
6 Per Lord Denning in the Privy Council case of
7 See WP Keighery Pty Ltd v. Federal Commissioner of Taxation (1957) 11 ATD 359.
8 See Mullens v. FCT (1976) 6 ATR 504.
9 The GAAR in the Stamp Duties Act is in essence identical to the GAAR found in section 33 of the Act.