Guide, 6 min read

Tax and stamp duty: what sellers should ask about

Share sale versus asset sale, stamp duty on share transfers, and where the tax consequences differ. General information, not advice.

This is general information about how Singapore business sales are usually structured. It is not tax or legal advice, and the right answer depends on your specific position. Take advice before you agree the structure, not after.

Share sale versus asset sale

In a share sale you sell the shares in the company. The company continues, carrying its history, contracts and liabilities with it. Most sellers prefer this.

In an asset sale the company sells selected assets and the buyer leaves the liabilities behind. Most buyers prefer this. Proceeds land in the company rather than with you personally, which raises a second question about how you then extract them.

Which structure applies is negotiable, and it is one of the more consequential things in the term sheet.

Stamp duty on share transfers

Share transfers in Singapore attract stamp duty, calculated on the higher of consideration or net asset value, and payable within a set window after execution. Who bears it is a matter of agreement, and it should be written down rather than assumed.

Unstamped or late-stamped historic transfers are a very common diligence finding in older SMEs. They are fixable, but penalties may apply and the remediation takes time. Check the register of members and the past transfers before you go to market, not during diligence.

Capital gains

Singapore does not tax capital gains. Whether a particular gain is capital in nature, rather than income from a trade, depends on the facts. Owners who buy and sell businesses frequently should take specific advice on this point.

GST and employees

Asset sales raise GST questions, including whether a transfer of a going concern applies. Employees transferring across raise their own set of obligations. Both need handling in the sale agreement rather than after completion.

The practical point

Structure affects net proceeds materially, sometimes more than a further round of price negotiation would. Bring your tax advisor in when the term sheet is being drafted, which is early enough to change the structure, rather than at completion, which is not.

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