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5.6. Qualification of Specific Income Categories for Tax Purposes

Dividend Income

The term ‘dividend’ means any amount distributed, whether in cash or otherwise, by a company to its shareholders, including:

  • the sale, lease, exchange or relinquishment of the asset or the extinguishment of any rights in the asset;
  • the compulsory acquisition of the asset under any law;
  • the conversion by the owner of a capital asset into stock-in-trade of a business carried on by the owner; or

any transaction which has the effect of transferring or enabling the use or enjoyment of any immovable property.


The term ‘interest’ includes interest on loans advanced, interest on receivables, etc. Effective 1 July 2019, the scope of the term ‘interest’ has been widened to include loan-raising or establishment fees, guarantee fees and any fees economically equivalent to interest.


The term ‘royalty’ means any amount payable for the use of, or the right to use, any copyright of literary, artistic or scientific work (including cinematograph films, and films or tapes for radio or television broadcasting) any patent, trademark, design or model, plan, secret formula or process, industrial, commercial or scientific equipment and the right to commercially develop and exploit software.

Service Fees

Management and consultancy fees include any amount payable for administrative, managerial, technical or consultative services or any similar services, whether such services are of a professional nature or not, including the development or customization of software.