The tax for foreign sourced disposal gains will be subject to tax only for those entities that do not have an economic substance in Singapore. The test for economic presence is subjective and will be assessed on a case by case basis. This change is to align with international standards on Base Erosion and Profit Shifting (BEPS) framework. The change is not anticipated to have an adverse impact on the Singapore economy but the compliance burden may increase to prove a direct nexus between the income receiving benefits and the expenditure contributing to that income especially as it relates to intellectual property rights.