3 doctors fail in court challenge against IRAS ruling over tax avoidance scheme | The Straits Times   https://www.straitstimes.com/singapore/courts-crime/3-doctors-fail-in-court-challenge-against-iras-ruling-over-tax-avoidance-scheme   This case involves three prominent private practice obstetricians and gynaecologists (O&Gs)—**Dr. Adrian Tan Chek Jin, Dr. Caroline Khi Yu May, and Dr. Jocelyn Wong Sook Miin**—who lost their High Court appeal against the Inland Revenue Authority of Singapore (IRAS). The core of the dispute centers on Section 33 of the Income Tax Act, which gives IRAS the power to disregard any corporate structures or arrangements designed primarily for tax avoidance and to re-assess the individuals as if the scheme didn't exist.   The specific details of the multi-layered corporate structure, the timeline of events, and how the tax savings were generated provide a clear breakdown of the case.   ### The Corporate Restructuring Scheme   Before entering private practice, the three doctors were colleagues at KK Women's and Children's Hospital (KKH). When they transitioned to the private sector in 2004, they established a joint practice, which they later fragmented into individual companies over two distinct rounds of restructuring:    * **Round 1 (Initial Setup - 2004):** They incorporated a joint company called **ACJ Women's Clinic (ACJW)**. Each doctor was a director and held a one-third stake. Each signed an employment contract drawing a modest salary of $5,000 a month.    * **Round 2 (Individual Holding Companies - 2005 to 2007):** They set up separate personal medical companies: Dr. Tan created *AT OG Services*, Dr. Khi created *CKYM Holdings*, and Dr. Wong created *JW Medical Holdings*.    * **Round 3 (Surgical Companies - 2014):** They fragmented the practice further by setting up individual surgical companies (*ACJ Tan Surgery*, *CKHI Surgery*, and *Joy Wong Surgery*).   **The Division of Business:** The outpatient services were billed under the joint company (ACJW), while inpatient services and surgeries were invoiced through their respective personal surgical companies. Under these new surgical entities, they signed contracts raising their monthly salaries only slightly to $6,000.   ### How the Tax Avoidance Worked   By suppressing their personal employment salaries and routing the earnings through multiple corporate layers, the doctors took advantage of two specific tax loopholes:    1. **Exploiting Small Business Exemptions:** Splitting a single large practice into multiple smaller individual companies allowed them to repeatedly claim tax rebates under the **Start-Up Tax Exemption (SUTE)** and the **Partial Tax Exemption** schemes, lowering the overall corporate tax rate significantly.    2. **Extracting Wealth via Dividends and Loans:** Instead of taking a market-rate salary (which would be hit by top-tier individual income tax brackets up to 22%), the doctors paid themselves low salaries. The rest of the company profits were extracted as **high tax-exempt dividends** or **interest-free shareholder loans**.   For context, during the audited years of 2013 to 2018, Dr. Adrian Tan (the most senior doctor) was drawing a base salary of just $5,000 to $6,000 a month—despite making $45,600 a month before even leaving the public sector. Instead, he extracted **$5.14 million** and **$2.35 million** in dividends from two of the firms, alongside up to **$2.1 million** in shareholder loans.   ### The Timeline: Audits to High Court Dismissal    * Attempted Striking-Off    2016      The doctors attempted to dissolve and strike off their personal medical holding companies (AT OG Services, CKYM Holdings, and JW Medical Holdings).    * IRAS Intervention & Audit    Late 2016      IRAS objected to the striking-off application of one of the firms and initiated a comprehensive tax audit into the doctors' corporate arrangements.    * Claw-Back Assessment    Oct & Dec 2019    IRAS invoked Section 33 of the Income Tax Act. In October, it issued amended individual income tax assessments for 2013–2018 to tax the corporate earnings directly under the doctors' names. In December, it clawed back corporate tax benefits from business fragmentation for the year 2015.    * Board of Review Appeal    Pre-2026    The doctors appealed the re-assessments to the Income Tax Board of Review. The board ruled in favor of IRAS, finding that the business structures lacked commercial justification and were built to secure tax advantages.    * High Court Dismissal    June 18, 2026      Justice Alex Wong dismissed the doctors' final challenge. He noted that Dr. Tan could not explain why his salary stayed low while the practice's profitability soared, concluding that the structure lacked a genuine commercial purpose.   ### The Legal Verdict & Takeaway   Justice Alex Wong upheld the Board of Review's findings, highlighting that this case is "the latest of several cases where medical professionals have run afoul of the tax authorities" due to artificial business structuring. Because the doctors could not provide a reasonable commercial explanation for why they kept their salaries artificially suppressed while pulling millions out through tax-exempt avenues, the High Court agreed that IRAS was entirely justified in treating the setup as a tax avoidance scheme and re-taxing the income at individual rates.

he got a card for diving in last game, joke also lol

miss the whole game, but knn turks wtf lol   1st game and today both toothless   the guler still think he mega super star? he just a normal star at most lol

Expected la .. means the info inside also kena leaked