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SOURCES OF INCOME(3B&4) (SECTION 10(1)(d) DIVIDENDS, INTERESTS OR…

- - - - FACTORS TO CONSIDER WHEN ESTABLISHING THE EXISTENCE OF TRADE
        
        SUBJECT NATURE of the asset
        
        Length of period of ownership(if short then most likely trading)
        
        Frequency of similar transactions( if its high, then most likely trading)
        
        SUPPLEMENTARY WORK done to the asset to make it more marketable
        
        PROFIT SEEKING NATURE( the intention of the buyer)
        
        CIRCUMSTANCES RESPONSIBLE for the realization( if forced to sell asset to return debt, then most likely not a trade
        
        The WAY which the asset was acquired( can tell whats the intention behind it)
        
        Whether a man already has interest in the same trading field( did he did similar things before)
        
        The method of financing ( may purposely borrow money to buy the land)
        
        The destination of the proceeds
      - IN SINGAPORE OR WITH SINGAPORE
        
        IN SINGAPORE: sourced and taxable in singapore
        
        with Singapore:income is sourced outside Singapore and not taxable
        
        Also need to be PERMANENT establishment
        
        Fixed place where business is wholly or partially carried on including place of management, a branch, an office, a factory
        
        will deemed to have PE if person carried in supervisory activities in building or work site
        
        has another person acting on his behalf in Singapore who obtains order from him, has the authority to conclude contracts and maintains merchandise for delivery to customers
    - - Activity that requires Intellectual skill or manual skill E.g Dentists, Lawyers
      - Vocation---similar to 'Calling" (taxi driver, minister of region)---not allowed to claim capital allowances unlike others.
    - - E.g Year ended--31 Jan 2017 Basis Period 1.2.2016 to 31.1.2017
      - ACCOUNTING PERIOD IS MORE THAN 12 MONTHS
        
        Temasek Pte Ltd was incorporated on 1 April 2016 .It makes up its first set of accounts to 30 June 17
        The trading profits for Tax purposes were $15,000 for the
        period
        What is the amount of profits to be assessed for the relevant
        years of Assessment ?
        YA 2017 :3 months(3/15 x 15k = $3,000
        YA 2018: 12months(12/15 x 15k)= $12,000