SINGAPORE BUDGET 2020 WISHLISTEntering the World of Virtual Currency

SINGAPORE BUDGET 2020 WISHLISTEntering the World of Virtual Currency

Index
Tax exemption scheme for new start-up companies ............................................................................ 3
Companies dealing with trade while holding investment .................................................................... 3
Encouraging continuous learning .......................................................................................................... 3
Financial support for acquisition of intellectual properties ................................................................. 4
Funding support for digitalisation ......................................................................................................... 4Entering the world of virtual currency .................................................................................................. 4Bank account opening for companies dealing with virtual currencies ................................................ 5Support for families................................................................................................................................ 52

SINGAPORE BUDGET 2020 WISHLISTEntering the World of Virtual Currency

Tax exemption scheme for new start-up companies
Thankful for the tax exemption scheme, we guess most of the companies had benefited from thisexemption during the first three Years of Assessment (“YAs”) since their incorporation.
Notwithstanding so, there are still a group of businesses who are not profitable in the first threeYAs, and hence, unable to enjoy the above privilege as a start-up company.
We would suggest that, the tax exemption for new start-up companies could be enhanced byclaiming it on the first three YAs, starting from the YA when a company starts deriving chargeable
income. To further motivate new start-ups in generating their business profit, deadline could beset for claiming the tax exemption, say, by the fifth YA.

Companies dealing with trade while holding investment
Currently, for company’s principal activity is that of investment holding, only investment income
such as interest, dividend or rental income will be taxed. Deductible expenses are statutory,
direct and indirect expenses. Capital allowance is not eligible for such company and excess
expenses over income is not allowed for carried forward to future YAs.
At the same time, for companies dealing with trade while holding investment, it is a common
practice that expenses incurred are not required to be allocated to the respective type of businessactivity. Further, unutilised losses are allowed for carried forward for such mixed businessstructure. However, such common practices are not publicly known nor stated in the Income TaxAct.
In this case, we would suggest the tax authority would provide more details on the tax treatmentof such mixed businesses entity, so as to give a clear understanding and guideline, particularly forforeign investors who wish to set up such business in Singapore.

Encouraging continuous learning
To encourage continuous learning and in ensuring employees keep abreast of the latest changes
in the respective industries, financial supports / tax relief or incentives should be given toemployers who are willing to send their employees for external trainings / seminars.
For example, we understand that there is course fee and absentee payroll funding in place, thecriteria for such funding should not be limited to employees who are above 35 years old andearning monthly income not more than S$2,000. Additionally, it should not be limited to courses
pre-approved by certain organisations but could be extended to those relevant to one’s
employment or profession.

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SINGAPORE BUDGET 2020 WISHLISTEntering the World of Virtual Currency

Financial support for acquisition of intellectual properties
We understand that the Singapore government has issued “Intellectual Property Hub Master Plan”
in year 2013. To continue encourage growing businesses with intellectual properties, we hope
the government could consider granting tax incentives or financial assistance for the acquisition
or development of intellectual properties, in order to turn the country in to a global hub for
intellectual properties’ development, registration, as well as protection.

Funding support for digitalisation
In line with the Government’s policy in supporting businesses to pursue digitalisation, we wish
that the funding support for digital transformation, for example, Productivity Solution Grant,
should be expenses to all SMEs.
Local shareholding requirement shall be lifted out so that all SMEs in order to encourage allbusinesses in bringing IT solutions into the business, so as to enhance the business productivity
and eventually, boost the Singapore’ economy through digitalisation.

Entering the world of virtual currency
Notwithstanding the rise of crypto and blockchain start-ups in Singapore, the accounting and tax
treatment, particularly on the determination of the nature of related business transactions
remain ambiguous at this juncture. Hence, instead of leaving the issuers, investors and even thirdparty advisors with uncertainty, we would appreciate it if the authorities could look into thematter and advise the public on the proper treatment of transactions that industry may have, forbetter tax planning.
Example of the issues that the industry is facing:• Criteria in determining the nature of virtual currency (i.e. revenue or capital)• The character of the virtual currency during an initial coin offering (“ICO”) (i.e. equity, debt
security or working capital)• Taxability of the gain from redemption of the virtual currency• The nature of ICO platform (i.e. website, intangible asset or R&D project)• Supporting documentation that needs to be maintained.

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SINGAPORE BUDGET 2020 WISHLISTEntering the World of Virtual Currency

Bank account opening for companies dealing with virtual currencies
As discussed in the earlier point, there are increasing number of businesses involving
cryptocurrencies, initial coin offerings and digital tokens in Singapore. In view of this, perhaps theSingapore government should look into the criteria in opening bank account with local financial
institution. We understand that the local banks are trying to adhere to the anti-money launderingand know-your-customer practices. Notwithstanding so, the day to day operation of these
affected companies will be disrupted without having a bank account in Singapore.
We would suggest local financial institutions to loosen its criteria in bank account opening forsuch companies, while imposing restriction in other areas, such as setting higher initial deposit,
increasing the minimum balance, limiting the remittance or withdrawal of uncommon
transactions, in order to minimize the risks in financing, rather than stopping such companies in
opening local bank accounts in Singapore.

Support for families
To continue encourage childbirth while remaining working mothers in the workforce, theGovernment could consider giving remuneration relief to employers who continue hiring working
mothers who work from home. This would be a win-win solution for young families to be able tolook after the new-borns while being able to support the family’s financial needs at the sametime.
Additionally, from the employer’s perspective, we would appreciate it if the reimbursement for
Government-Paid Maternity Leave could be extended from two to three months for first andsecond child.

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