Section 23C Notice: equity interests held under arrangements
The Section 23C notice tells the Commissioner of Stamp Duties that an arrangement has changed who beneficially owns equity interests in a residential property-holding entity.
This is the genuine IRAS PDF, unmodified. Source: IRAS official page.
What is Section 23C Notice?
Additional Conveyance Duties apply to transfers of equity interests in entities whose underlying assets are largely Singapore residential property. Where an arrangement means one party beneficially owns equity interests, or a higher percentage of them, and another owns none or a lower percentage, section 23C of the Stamp Duties Act requires that change to be notified to the Commissioner of Stamp Duties within 14 days.
The single page notice is set out in Parts A to E: the party who ends up beneficially owning the equity interests or a higher percentage, the party who ends up owning none or a lower percentage, the entity whose equity interests are involved, a description of the arrangement, and a confirmation signed by both parties. The notice covers trustees holding equity interests for a beneficiary who is not a bare trust beneficiary, since section 23(22)(aa) treats such a trustee as beneficially owning the interest.
Who files Section 23C Notice?
- Parties to an arrangement that changes beneficial ownership of equity interests in a residential property-holding entity
- Trustees holding equity interests for a beneficiary that is not a bare trust beneficiary
- Companies and their advisers restructuring shareholdings in property-holding entities
- Lawyers and tax agents preparing the notice for both parties to sign
How to fill out Section 23C Notice
- Print the notice and complete Part A with the name, identity type and identity number of the party who beneficially owns the equity interests or a higher percentage after the arrangement.
- Complete Part B with the details of the party who ends up owning none or a lower percentage of the equity interest.
- Complete Part C with the name and identity details of the entity whose equity interests are involved.
- Set out a detailed description of the arrangement in Part D, on a separate sheet if there is not enough room.
- Have both parties sign and date Part E, then submit the notice to the Commissioner of Stamp Duties at 55 Newton Road, Revenue House, Singapore 307987 within 14 days after the date of the change in beneficial ownership.
Get Section 23C Notice
IRAS publishes Section 23C Notice as a flat PDF with no built-in form fields, so there is no quick-fill form here. Open it in the editor to type directly onto the pages, tick boxes and sign, or download the official blank and complete it in your PDF reader or by hand.
Frequently asked questions
How is the Additional Conveyance Duty worked out?
The notice states that the ACD payable on the increase or decrease of equity interest is calculated based on the market value of the underlying residential properties. IRAS publishes the rates in its e-Tax Guide on Stamp Duty: Additional Conveyance Duties (ACD) on Property-Holding Entities.
Who has to sign the notice?
Both parties. Part E is a joint confirmation, with a signature block for the party named in Part A and one for the party named in Part B.
What happens after the notice is filed?
The Commissioner of Stamp Duties may request further information. Keep the underlying agreements and valuations available so you can respond quickly.