Everything You Need To Know About Tax in Singapore (By PWC)
Everything You Need To Know About Tax in Singapore (By PWC)
Everything You Need To Know About Tax in Singapore (By PWC)
2008 Singapore
(Incorporating 2008 Budget Proposals)
This publication, which will be updated annually, contains handy reference tables
and other information for individuals and corporations to help them quickly
ascertain their income tax liability. As rates and other information may change as a
result of legislation or regulation issued after this booklet went to production, the
information contained here should be used for guidance only and further
information should be sought from our organisation. No liability can be accepted
for any action taken as a result of reading the contents without consulting us with
regard to all relevant factors. All amounts shown in this publication are in
Singapore dollars.
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Employer’s Obligations
• Central Provident Fund Contributions 10
• Skills Development Levy 11
Estate Duty 11
Stamp Duties 14
Capital Allowances 15
Tax Incentives 16
Non-Fiscal Incentives 48
Due Dates 53
Basis of Taxation
Income is taxable when it accrues in or is derived from Singapore.
Employment income, which includes salaries, bonuses, allowances, perquisites and benefits in kind, is
taxable in Singapore if the employment is exercised in Singapore. Generally, this is regardless of where the
employer is situated, where the remuneration is paid or which entities benefit from the services.
Income derived from sources outside Singapore is taxable only if it is received in Singapore by a resident
individual through a partnership in Singapore.
Capital gains are not taxable in Singapore. However, if the individual enters into a series of capital
transactions, the Inland Revenue Authority of Singapore (IRAS) may take the view that he is carrying on a
business and assess him to income tax accordingly.
Residence
An individual is resident in Singapore if he:
• is physically present or exercises an employment (other than as a director of a company) in Singapore for
183 days or more during the basis year.
• stays in Singapore for a consecutive period spanning 3 calendar years (not necessarily 3 complete
calendar years); or
• enters Singapore on or after 1 January 2007 and stays or works in Singapore for a continuous period of at
least 183 days spanning 2 calendar years.
1
Individual Income Tax Rates (Years of Assessment 2008 to 2009)
Resident Rates
Chargeable
Rate % Tax $
Income $
Non-Resident Rates
Type of Income %
Director'
s remuneration 20
Entertainer'
s professional income 15
Employee'
s remuneration 15
(However, where the tax calculated on resident rates is higher, the resident rates are
used)
Other income 20
(Where not specifically exempt)
Note: 1) Non-resident taxpayer may make an irrevocable option to be taxed at 20% of net income.
2) Not available to company directors and entertainers.
2
Tax Exemptions/Relief for Individuals
• Full exemption for:
− interest income derived from all deposits with approved banks and financial institutions.
− Singapore-sourced investment income from certain financial instruments derived by resident and
non-resident individuals.
− one who is neither resident in, nor a citizen of Singapore, but is resident in another country which has a
double taxation agreement with Singapore.
The tax relief reduces the amount of tax payable to an amount arrived at as follows:
Singapore citizens and permanent residents who have worked for at least 6 months overseas in any
calendar year could be considered as non-resident.
• has not been a Singapore tax resident in the 3 years of assessment preceding the year in which he first
qualifies for the NOR scheme; and
• is a Singapore tax resident for the year of assessment in which he wishes to qualify for the scheme.
A NOR will enjoy the following benefits (subject to prescribed conditions and capping limits):
• time apportionment of income from Singapore employment (w.e.f. Year of Assessment (YA) 2009, this
includes commuted leave and benefits-in-kind, but excludes directors’ fees) by reference to time spent
outside Singapore on business;
• remittance of pre-assignment income (no longer relevant with the blanket exemption on all foreign-sourced
income received by individuals).
3
Resident Taxpayer’s Personal Reliefs
Aged parent or grandparent maintained by the taxpayer (note 2) $3,500 for each dependant
Aged parent or grandparent living with the taxpayer (note 2) $5,000 for each dependant
Handicapped dependant (spouse or sibling) living with or maintained by $3,500 for each dependant
the taxpayer (note 3)
Notes: 1) Dependant' s income must not be more than $2,000 in the basis year.
2) Aged parent or grandparent relief can be claimed for a maximum of 2 dependants. For each of the handicapped
parents, $3,000 is claimable in addition to the aged parent relief.
3) Husband claiming this relief for his wife does so in lieu of normal wife relief.
• Contributions to top up the CPF retirement account under the CPF Prior to YA 2009, combined
Minimum Sum Topping-Up Scheme: relief of up to $7,000 per annum
for (i) and (ii).
i) by the taxpayer or his employer (w.e.f. 1 November 2008) to the
taxpayer’s account; and From YA 2009, separate relief
granted of up to $7,000 per
ii) by the taxpayer to the accounts of a non-working spouse or annum for each of (i) and (ii).
sibling, a parent or grandparent. The spouse or sibling must have
income of less than $2,000 in the basis year. Prior to YA 2009,
the spouse, sibling, parent or grandparent had to be at least 55
years of age in the basis year.
• Contributions to top up CPF healthcare account (Medisave) of the No relief prior to YA 2009.
taxpayer.
From YA 2009, relief of up to
$26,393 per annum, less
mandatory contributions.
4
Resident Taxpayer's Personal Reliefs (continued)
NSman Relief
Claimable by: Active Non-active
From YA 2009, the relief is available regardless of whether the course is relevant to the taxpayer' s current
occupation or business. Subject to certain conditions, the taxpayer can claim the relief within 2 years of
assessment from the year in which the course is completed.
5
Resident Taxpayer's Personal Reliefs (continued)
• Handicapped Child Relief (HCR) (note 1 & 2) – Relief of $3,500 per child is claimable in lieu of QCR.
• Parenthood Tax Rebates (PTR) (note 3) – Claimable by either parent or shared between both parents for
Singapore citizen children who are born on or after 1 January 2004 to a married, divorced or widowed
parent or to unmarried parents who subsequently marry before the child reaches 6 years of age; or legally
adopted by a married, divorced or widowed parent on or after 1 January 2004. Children adopted on or after
1 January 2006 must be adopted before they reach 6 years of age.
PTR replaced the Special Tax Rebate from YA 2005, but a transitional rebate of $20,000 and $15,000 was
available for mothers who gave birth to their second child in 2004 before they reached 28 and 29 years of
age respectively.
• Grandparent Caregiver Relief (GCR) (note 3) – Relief of $3,000 is claimable by working mothers
(including widows and divorcees) who have Singapore citizen children aged 12 years or below.
• Working Mother's Child Relief (WMCR) (notes 1, 2 & 3) – Claimable by working mothers (including
widows and divorcees) who have Singapore citizen children.
WMCR replaced Enhanced Child Relief and Further Tax Rebates from YA 2005, but a transitional Further
Tax Rebate of 15% of the mother’s earned income was allowed for mothers who gave birth to their third or
fourth child in 2004, capped at $20,000 or $40,000 respectively.
Note: 1) The child must be below 16 years of age, in full-time education or handicapped and his income must not be more
than $2,000 in the basis year.
2) The total amount of child relief (i.e. including QCR/HCR & WMCR) for each child is capped at $25,000.
3) Conditions apply.
6
Tax Treatment of Employment Fringe Benefits
Accommodation:
Overseas travel:
• Home leave passage • Actual amount paid by employer for Singapore citizen and SPR
employees.
• Per diem allowance for business • Amount in excess of acceptable rate published by IRAS (annual
trips rate for each country varies).
Transport:
• Car benefits • Private mileage on cars, rental cars, motorcycles and commercial
vehicles, computed based on IRAS formulae.
• Transport reimbursement/per-trip • Not taxable if for discharging official duties or overtime work.
allowance
7
Tax Treatment of Employment Fringe Benefits (continued)
Loans:
Gains from exercise of stock • Market value at exercise date or at the end of the moratorium
options and share ownership period, if any, less amount paid by employee.
plans
• Tax exemption available as follows (note 2):
i) Equity Remuneration Incentive Schemes (ERIS) (SMEs)
(formerly known as the Entrepreneurial Employee
Equity-based Remuneration Scheme) – 50% up to $10
million over 10 years.
ii) ERIS (All Corporations) (formerly known as the Company
Employee Equity-based Remuneration Scheme) – 100% on
the first $2,000 and 25% of the remainder up to $1 million
over 10 years.
iii) ERIS (Start-Ups) (introduced w.e.f. 16 February 2008) – 75%
up to $10 million over 10 years.
• Insurance premiums paid by • Not taxable if employer is the beneficiary of the policy or if no
employer beneficiary is named.
• Medical and health insurance • Not taxable if policy is generally available to all staff.
benefits, including reimbursements
of non-basic medical care
• Medisave account in lieu of • Not taxable up to $1,500 per employee per year.
hospitalisation benefits
8
Tax Treatment of Employment Fringe Benefits (continued)
Retirement benefits:
• Upon withdrawal:
• Employer'
s contributions to • Amount in excess of statutory limit (see page 10).
employee'
s CPF accounts
• Contributions in respect of remuneration paid for duties
performed outside Singapore are not taxable, subject to
conditions.
• Benefits that foster goodwill or • Not taxable if policy is generally available to all staff.
promote camaraderie among staff
9
Tax Treatment of Employment Fringe Benefits (continued)
• Awards for good performance, long • Generally not taxable if non-cash award and the value does not
service, retirement, etc exceed $200 (w.e.f. YA 2008).
• Certain cash awards are not taxable if the amount does not
exceed $200 (w.e.f. YA 2008).
• Gifts for special occasions • Not taxable if policy is generally available to all staff and the
amount does not exceed $200 (w.e.f. YA 2008).
Other benefits:
• Childcare benefits • Not taxable if the child attends a licensed childcare centre.
Employer’s Obligations
Except for employees over 35 who are earning less than $1,500 per month and those above 50, the
employer, from 1 July 2007, will have to contribute 14.5% and the employee, 20% of:
• ordinary wages paid in cash (e.g. monthly salary), up to a maximum contribution of $652.50 and $900 per
month, respectively; and
- the actual additional wages if the annual ordinary wages is not more than $54,000 and the total wages
is not more than $76,500;
- the difference between $76,500 and annual ordinary wages if the total wages exceed $76,500 but the
annual ordinary wages is not more than $54,000; or
- the lower of $22,500 or the actual additional wages if annual ordinary wages exceed $54,000.
The detailed CPF contribution rates for employers and employees are available from the CPF Board’s
website at http://www.cpf.gov.sg
Foreign employees are exempt from CPF contributions unless they become SPRs. Foreign employees who
become SPRs, and their employers, may contribute at reduced rates for the first 2 years.
10
Employer’s Obligations (continued)
The SDF is used to provide grant incentives to Singapore-incorporated companies to mount training
programmes for employees. Incentives are offered on the basis of a cost-sharing principle and the training
must be relevant to the economic development of Singapore. The amount of incentives that a company can
obtain is not tied to the levy contribution.
The SDF is administered by the Singapore Workforce Development Agency with the CPF Board as the
collecting agent.
Estate Duty
Estate duty does not apply for deaths occurring on or after 15 February 2008.
The estate duty rates in the case of persons who died between 28 February 1996 and 14 February 2008 are
shown in the following table:
Above 12,000,000 10
i) The following are not included in the estate for the purposes of calculating the duty:
a) the first $9 million of the aggregate value of residential houses in Singapore which the deceased
owned;
b) $600,000 of the aggregate value of all other property; and
c) the excess over $600,000 (if any) of the aggregate amount standing to the credit of the deceased in
the CPF and in any designated pension or provident fund.
ii) Bequests to approved institutions are deductible from the principal value of the estate.
iii) Where the deceased was not domiciled in Singapore, only his immovable property in Singapore above
the exemption threshold of $9 million (see (i)(a) above) is subject to estate duty.
iv) From 1 January 2006, estate duty relief is available for deaths in quick succession. The rate of relief
depends on the time period between the deaths:
> 24 months 0%
11
Partnerships, Trusts, Estates, Charities and Mutual Concerns
Form Basis of Assessment Rate of Tax
Partnership • Each partner is assessed separately on his share of the At the rates applicable
divisible income of the partnership. to status of partner.
Limited • Separate legal entity with flow-through tax treatment, with At the rates applicable
Liability restrictions imposed on the share of losses, unabsorbed to partner.
Partnership capital allowances and industrial building allowances by
reference to capital ingested.
Trust • Generally, the trustee is assessed on trade income of the trust Prevailing corporate
and investment income of non-resident beneficiaries. rate.
Distributions out of such income are exempt to the
beneficiaries. Investment income of Singapore-resident
beneficiaries is given flow-through tax treatment.
• Where entitlement to the trust income passes, the At the rate applicable to
Singapore-resident beneficiary is assessed on his share of the status of beneficiary.
income.
Estate • The executor is assessed on the income of the estate. For Prevailing corporate
estates administered in Singapore, a deduction is allowed for tax rate.
income received by, distributed to or applied for the benefit of
beneficiaries before 31 March of the year following the year of
assessment.
• The beneficiary is assessed on the income for which the At the rate applicable to
executor was allowed a deduction. status of beneficiary.
Charitable • All charities registered or exempt from registration under the Not applicable.
Institution Charities Act are exempt from YA 2008.
Club and • Exempt from tax if more than half of its gross receipts If taxable, at graduated
Others (including entrance fees and subscriptions) are received from rates, subject to
members. maximum effective
corporate tax rate,
• Interest and rental income are taxable after deducting which is calculated as if
appropriate expenses. the body of persons is
a company and the
Trade • Receipts from transactions with non-members are taxable. effective rate is based
Association on:
• From YA 2008, income from transactions with Singapore Tax payable on
members is exempt from tax if not more than half of receipts chargeable
from entrance fees and subscriptions are from Singapore income (CI) net of
persons who claim or are entitled to claim deductions for such partial tax
sums. exemption
CI before deducting
• From YA 2008, income from transactions with foreign partial tax
members is exempt. exemption
12
Corporate Income Tax Rates (Years of Assessment 2008 to 2009)
Corporate Tax %
• Foreign-sourced dividends, branch profits and service fee income remitted to Singapore Exempt
from a foreign jurisdiction where the headline tax rate is 15% or more and where tax has
been paid.
Withholding Tax
Withholding tax must be deducted from certain payments to non-residents. The domestic rates for certain
payments made on or after 1 January 2008 are provided below. Tax incentives (see page 16) or double
taxation agreements (see page 49) may provide for exemption or reduction of these rates.
i) interest 15
iii) royalties 10
iv) copyright royalties in respect of literary, dramatic, musical or artistic work or approved 18 or 20
invention/innovation (note 2)
viii) director'
s remuneration 20
xi) real estate investment trust (REIT) distributions to non-individuals out of certain 10
income
xiii) payments for the use of any facility or equipment in a space satellite Exempt
xiv) payment for the indefeasible right to use any international telecommunications Exempt
submarine cable system (IRU)
xv) commission or other payments to a junket promoter for arranging a junket with a 3
casino operator in Singapore (w.e.f. 2 April 2008)
Notes: 1) Partial exemption of up to $152,500 applies to first $300,000 of the company' s chargeable income (excluding
Singapore taxable dividend income). Full exemption on the first $100,000 of chargeable income (excluding
Singapore taxable dividend income) is available for a new company' s first 3 consecutive years of assessment,
subject to conditions.
2) The higher rate applies if the payee is an individual. In addition, where the payee files a tax return, the maximum
taxable income is 10% of gross income.
3) The payee may opt to be taxed at 20% on net income.
13
Other Tax Rates
Goods And Services Tax (GST) %
Export of goods and international services from Singapore and certain trustee services 0
Certain financial services, sales and lease of residential land and buildings Exempt
Companies under the Approved Contract Manufacturer & Trader Scheme Out of scope
Gains that are of a capital nature are not taxed in Singapore. However, where there is a series of transactions
or where the holding period of an asset is relatively short, IRAS may take the view that a business is being
carried on and attempt to assess the gains as trading profits of the company.
Reliefs/Remissions
14
Capital Allowances
Categories Capital
Allowance
%
− initial allowance 20
− annual allowance Varies (note 1)
However, accelerated allowance is available in lieu of the above for capital expenditure
incurred on:
− machinery or plant costing less than $1,000 each (subject to an annual cap of
$30,000)
− computer equipment
− prescribed automation equipment
− robot 100
− generator
− approved highly efficient pollution control and energy-efficient equipment
− approved noise reduction and chemical hazard control equipment
− replacement of old diesel-driven goods vehicle or bus, subject to certain conditions
− initial allowance 25
− annual allowance 3
However, for capital expenditure incurred on hotels on the island of Sentosa (approved
before 1 September 2007) and for tourist industry projects other than hotels:
− initial allowance 20
− annual allowance 2
Notes: 1) 80% of cost to be claimed over the prescribed useful life ranging from 5 to 16 years.
2) Applies to cost-sharing agreements entered into and approved on or after 17 February 2006. Prior to this, the rate
was 20%.
3) For capital expenditure incurred during or after the basis period for YA 2004.
4) Capital expenditure incurred to be claimed over the number of years for which the IRU is acquired.
15
Tax Incentives
SUMMARY CHART
MANUFACTURING SERVICES TRADE
INVESTMENTS FINANCE
LOCAL OVERSEAS
16
Tax Incentives – Manufacturing/Services
Type ++ Requirements Incentives Relief Period
• Pioneer EDB Projects must result in the creation Tax exemption on 5 to 15 years.
Enterprise of new industries or strategically qualifying profits.
expand existing industries in
Singapore.
• Approved EDB Loan must be obtained for the Exemption of Indefinite until
Foreign Loan purchase of productive equipment withholding tax on the loan is
Incentive and of a minimum amount of interest payable to repaid.
(AFL) $200,000. non-residents.
• Development EDB Projects must generate significant Tax rate as low as Up to 10 years
and economic spin-off for Singapore. 5% on incremental with provision
Expansion qualifying profits. for extensions
Incentive up to a
(DEI) maximum total
relief period of
20 years.
17
Tax Incentives – Manufacturing/Services (continued)
Type ++ Requirements Incentives Relief Period
• Pioneer EDB Projects must result in the creation Tax exemption on 5 to 15 years.
Service of new industries or strategically qualifying profits.
Companies expand existing industries in
Singapore.
18
Tax Incentives – Services (continued)
Type ++ Requirements Incentives Relief Period
19
Tax Incentives – Services (continued)
Type ++ Requirements Incentives Relief Period
b) perform a minimum of 3
qualifying headquarters
services to network entities in 3
countries outside Singapore by
the end of year 1 of the
incentive period;
20
Tax Incentives – Services (continued)
Type ++ Requirements Incentives Relief Period
IHQ companies that are approved Gains from sale of 5 years with
holding companies (AHCs) must shares in approved window
own at least 50% of the ordinary subsidiary approval period
shares in approved subsidiary companies will be from 17
companies for a minimum period of treated as capital February 2006
18 months continuously: gains and not subject to 16 February
to tax. 2011.
i) immediately prior to the date of
disposal of shares; and
• Approved MPA Singapore tax resident companies i) Tax exemption 10 years with
International with worldwide networks and good on: provision for
Shipping track records which: extension up to
(AIS) a) qualifying a maximum
Enterprise i) are significant owners and/or shipping and total of 30
operators of a fleet of ships, or charter hire years.
ship leasing companies whose income;
ships are chartered for
qualifying purposes under b) dividends
operating lease; from approved
subsidiaries
ii) have total business spending in and
Singapore of at least $4 million associated
per annum; shipping
companies;
21
Tax Incentives – Services (continued)
Type ++ Requirements Incentives Relief Period
g) foreign Indefinite.
exchange
gains and
gains from risk
management
activities.
a) charter
payments to
qualifying
overseas
shipping
companies.
b) interest,
front-end and
commitment
fees payable
on an
approved loan
to a lender
outside
Singapore.
22
Tax Incentives – Services (continued)
Type ++ Requirements Incentives Relief Period
• Approved MPA Ship agencies, ship management, Tax rate as low as 5 years (10
Shipping & international freight forwarders or 10% on service years w.e.f. 15
Logistics international logistics operators income and February 2007).
(ASL) which: management fees
Scheme received by the
i) have established operations approved company in
with good track records in the connection with
provision of freight and logistics freight and logistics
services; services.
23
Tax Incentives – Services (continued)
Type ++ Requirements Incentives Relief Period
e) foreign Indefinite.
exchange and
gains from risk
management
activities.
• Freight Uplift # Ship owners and charterers deriving Tax exemption on Indefinite.
freight income from uplift from freight uplift from
Singapore. Singapore.
• Approved STB Event companies organising or 10% tax on income For tourism
Mega Events staging world-class events and derived from qualifying events approved
activities. tourism events. from 1 April
2005 to 31
March 2010.
24
Tax Incentives – Trade
Type ++ Requirements Incentives Relief Period
d) employ a commensurate
number of experienced
trading professionals in
Singapore;
e) contribute to manpower
training and development of
trading expertise in
Singapore;
25
Tax Incentives – Trade (continued)/Investments
Type ++ Requirements Incentives Relief Period
b) primarily engaged in
innovative and high-growth
activities with substantial
development content for
specific products,
processes or services; and
c) incorporated in Singapore
with business activities
primarily in Singapore.
26
Tax Incentives – Investments (continued)
Type ++ Requirements Incentives Relief Period
• Asset MAS Approved Special Purpose i) Tax exemption for Date of transfer
Securitisation Vehicles (ASPVs) incorporated in income derived of assets into
Singapore to conduct asset from asset ASPV to latest
securitisation activities. securitisation maturity date of
arrangements securities issued
The ASPV must: entered into within the period
between 27 from 27 February
i) carry out all transactions at February 2004 and 2004 to 31
arm' s length; it must not have a 31 December December 2013;
profit motive; 2013. and entire
duration of
ii) not carry out any activity other ii) Withholding tax contracts
than those ancillary to the asset exemption for entered into
securitisation purpose for payments on between 27
which it was established; over-the-counter February 2004
(OTC) financial and 31
iii) not carry out the asset derivatives. December 2013.
securitisation with tax
avoidance as its purpose; iii) Fixed GST
recovery rate of
iv) have an issued and paid up 76% on all
capital of not more than business
$10,000. W.e.f. 5 November expenses incurred
2007, this condition may be during the
relaxed for Special Purpose incentive period,
Reinsurance Vehicles (SPRVs) regardless of the
registered under the Insurance input tax recovery
Act; formula of the
originator.
27
Tax Incentives – Investments (continued)
Type ++ Requirements Incentives Relief Period
• Maritime MPA i) Approved Ship Investment 10% tax on qualifying 10 years, with
Finance Manager (ASIM) incorporated in management income. window
Incentive Singapore to manage an approval period
(MFI) Approved Ship Investment from 1 March
Vehicle (ASIV). 2006 to 28
February 2011.
b) Singapore-registered ships
or foreign-registered ships
to AIS companies.
28
Tax Incentives – Investments (continued)
Type ++ Requirements Incentives Relief Period
• Resident MAS The fund must: Tax exemption for Indefinite, with
Funds specified income from window
i) be a company incorporated and designated approval period
tax resident in Singapore; investments. from 17
February 2006
to 16 February
2011.
29
Tax Incentives – Investments (continued)
Type ++ Requirements Incentives Relief Period
• Approved MAS/ Any unit trust scheme approved for Tax exemption for the Indefinite.
CPF Unit CPF the purpose of any investment unit trust for income
Trust scheme under the Central and gains from
Provident Fund Act. designated
investments.
30
Tax Incentives – Investments (continued)
Type ++ Requirements Incentives Relief Period
31
Tax Incentives – Investments (continued)
Type ++ Requirements Incentives Relief Period
• Foreign Trust MAS A trust created in writing or a unit Tax exemption for the Indefinite.
trust whose settlors and trust on qualifying
beneficiaries are: income.
32
Tax Incentives – Investments (continued)
Type ++ Requirements Incentives Relief Period
• Approved EDB Venture capital funds or venture Tax exemption on: Up to 10 years
Venture capital fund management with provision for
Company companies must: a) gains from extension up to
disposal of a maximum total
i) be incorporated and based in approved local and relief period of
Singapore; overseas 15 years.
investments;
ii) have obtained the necessary
approvals and licences from the b) dividends from
MAS for their proposed approved
activities; overseas
investments; and
iii) commit to invest a certain
percentage of their subscribed c) interest income
funds in Singapore and seed from convertible
stage and/or restart projects in loan stocks.
Singapore; and
Tax rate of not more
iv) commit to employ a certain than 10% during
number of local venture capital extension period.
professionals to manage the
approved venture capital funds.
etc.) performed
within or outside
Singapore and
overseas project
income relating to
approved
qualifying projects.
b) maintain at least 4
professional staff in
headquarters services;
34
Tax Incentives – Finance (continued)
Type ++ Requirements Incentives Relief Period
• Start-up Fund MAS The fund manager must be a 12 months to meet the First 12 months
Managers company which: requirements under of a new fund
the FSI-FM scheme set up during the
i) holds a capital markets services (see page 34). period 18
licence for fund management February 2005
under the Securities and Tax exemption for to 17 February
Futures Act or is exempted from specified income 2010.
holding such a licence; and derived by investors
(both foreign and
ii) has less than 3 years of local) from designated
corporate track record in the investments.
fund management business.
10% tax on fee
income derived by
qualifying FSI-FM
fund managers from
managing the fund.
36
Tax Incentives – Finance (continued)
Type ++ Requirements Incentives Relief Period
• Securities MAS The company must be: 10% tax on income From 18
Borrowing from the loan of, or February 2005
and Lending i) an FSI-ST company; or arranging the loan of to 31 December
(SBL) all securities except 2008.
ii) a company registered with unlisted Singapore
MAS. shares.
• Futures MAS Company that is a futures member 10% tax on income Indefinite.
Members of of the SGX and transacting with: derived from
the Singapore transactions in gold
Exchange i) a bank or merchant bank that is bullion, commodity
(SGX) an FSI company; and financial futures
and spot transactions.
ii) another futures member of
SGX;
• Offshore MAS Company must be a member of the 10% tax on income Indefinite.
Commodity Singapore Commodity Exchange derived from
Futures Ltd or any other prescribed transactions in
Trading exchange and transacting with: specified futures
contracts.
i) an Asian Currency Unit of a
financial institution;
37
Tax Incentives – Finance (continued)
Type ++ Requirements Incentives Relief Period
v) a foreign branch of a
Singapore-resident company;
38
Tax Incentives – Finance (continued)
Type ++ Requirements Incentives Relief Period
39
Tax Incentives – Finance (continued)
Type ++ Requirements Incentives Relief Period
Withholding tax
exemption on
payments in relation to
specified foreign
loans, bonds and
securities borrowing
and lending
arrangements where
the funds are used for
approved qualifying
activities and services
to approved network
companies.
• Approved MAS A licensed trustee company or one 10% tax on qualifying Indefinite.
Trustee exempted from holding a trust income.
Company business licence under the Trust
(ATC) Companies Act which provides
specified trust services to
non-residents in respect of
non-Singapore dollar investments.
b) dividends and
interest from
outside Singapore;
− Marine Hull General direct insurance and Tax exemption on: Up to 10 years.
and Liability reinsurance companies which:
Risks a) income from
i) employ at least 1 dedicated insuring and
marine hull and liability reinsuring relevant
underwriter with at least 5 years risks;
of relevant experience;
40
Tax Incentives – Finance (continued)
Type ++ Requirements Incentives Relief Period
41
Tax Incentives – Finance (continued)
Type ++ Requirements Incentives Relief Period
• Approved MAS Qualifying insurance brokers must 10% tax on income Up to 10 years,
Insurance/ be: from providing with window
Reinsurance insurance broking and approval period
Brokers i) direct insurance brokers advisory services to from 1 April
providing general insurance non-Singapore based 2008 to 31
broking business; or clients. March 2013.
42
Tax Incentives – Finance (continued)
Type ++ Requirements Incentives Relief Period
43
Tax Incentives – Finance (continued)
Type ++ Requirements Incentives Relief Period
44
Tax Incentives – Finance (continued)
Type ++ Requirements Incentives Relief Period
# No application required – incentive to be claimed upon submission of tax return to the IRAS.
45
Special Tax Deductions
Type ++ Requirements Benefit
• Patenting #/ Legal and economic ownership of the resulting Deduction for patenting
Costs EDB patent must accrue to the Singapore company. costs incurred from 1
Small and medium-sized companies must obtain June 2003 to 31 March
EDB’s verification that the invention has not 2013.
received support under the Patent Application
Fund Plus.
46
Special Tax Deductions (continued)
Type ++ Requirements Benefit
• Overseas IES Firms or companies resident and carrying on Double deduction for
Investment business in Singapore and at least 30% owned by approved expenses up
Development Singapore citizens of permanent residents which: to $200,000 relating to:
• Financial MAS Financial institutions engaged in the research and Further deduction for
R&D development of any approved new financial specified R&D expenses
Expenses activity. up to 30% of statutory
income.
• Public Art NHB i) Donation of public art or cash for the Double deduction for the
Incentive commissioning of artwork to an approved appraised value.
Scheme recipient.
(PATIS)
ii) Adoption of existing public art belonging to the Double deduction for
state or approved recipients. maintenance expenses
incurred.
IDA ii) Gifts of computers to prescribed institutions in Double deduction for the
Singapore or IPCs by corporate donors. assessed value.
# iii) Gifts of Singapore-listed shares and readily Double deduction for the
tradable units in unit trusts to approved IPCs by open market value.
individual donors.
• Employment MOM Companies which incur relocation and recruitment Further deduction for
of Talent expenses in hiring talents from abroad, subject to a prescribed expenses up
from Abroad maximum for each employee. to $275,000.
47
Special Tax Deductions (continued)
Type ++ Requirements Benefit
• Logistics EDB Singapore-resident companies that are end-users Further deduction of 30%
Expenses of logistics services which undertake, or outsource or 50% of expenses
to a service provider, significant regional or global incurred in relation to
logistics and supply chain activities in support of logistics activities,
their business activities. excluding international
freight charges.
• Share-based # Companies that incur expenses to acquire treasury Deduction for expenses
Remuneration shares to fulfil obligations under employee stock incurred to acquire the
option or share award schemes relating to treasury shares.
employment held in Singapore.
• Borrowing # Prescribed borrowing costs paid as a substitute for Deduction for prescribed
Costs interest expenses or to reduce interest costs. expenses (w.e.f. YA
2008).
# No application required – deductions to be claimed upon submission of tax return to the IRAS.
Non-Fiscal Incentives
Non-fiscal incentives are accorded to qualifying small and medium sized enterprise (SMEs). These are
administered by the various government agencies.
The intention of the guidelines is to help taxpayers substantiate their transfer prices with their related entities
by maintaining adequate documentation to mitigate the risk of tax adjustment by IRAS and to safeguard
them from potential economic double taxation. It also provides guidance on matters relating to Mutual
Agreement Procedures (MAP) and Advance Pricing Arrangements (APA).
48
Double Taxation Agreements
Singapore has concluded double taxation agreements with the following countries and the main reliefs are
summarised below. The rates listed are those negotiated under the treaties. Actual domestic rates will apply
if those rates are lower.
Indonesia Exempt 50% of normal 10% or 15% 10% (3b, e) 15% (4g)
rate (2c)
49
Double Taxation Agreements (continued)
Country Air Transport Shipping Dividends (2a) Interest Royalties
Luxembourg 50% of normal 50% of normal 5% or 10% (2b) 10% (3b) 10%
rate rate
50
Double Taxation Agreements (continued)
Country Air Transport Shipping Dividends (2a) Interest Royalties
South Korea Exempt Exempt 10% or 15% 10% (3b) 15% (4g)
(2c)
Sri Lanka Exempt 50% of normal 15% 10% (3a, b) 15% (4g)
rate
Sweden Exempt 50% of normal 10% or 15% 10% or 15% Exempt (4a)
rate (2b) (3b, c)
Thailand Exempt 50% of normal 20% generally 10% or 25% 15% (4g)
rate (3a, b)
51
Double Taxation Agreements (continued)
Notes:
1) a. Treaties signed but not yet ratified.
b. New treaty signed but not yet ratified.
c. Treaty applies with effect from 1 January 2009.
2) Dividends:
a. Singapore does not impose tax on dividends in addition to the tax chargeable on the profits or
income of a company; hence the rates shown reflect the position of the other treaty country.
b. Exempt if paid to the government.
c. Lower rate if the recipient is the beneficial owner of a minimum shareholding percentage, specified
in the respective treaties.
3) Interest:
a. Lower rate or exemption if received by a financial institution.
b. Exempt if paid to the government.
c. Exempt if paid by an approved industrial undertaking.
d. Exempt if paid by a bank and received by a bank.
e. Exempt if paid to bank but linked to government loan agreement or paid to specific financial
institutions/banks.
f. Exempt if paid in respect of an approved loan or indebtedness.
4) Royalties:
a. Royalties on literary or artistic copyrights, including film royalties, are taxed at non-treaty rates.
b. Lower rate for payments in respect of industrial, commercial or scientific equipment.
c. Lower rate for payments in connection with patents, designs, secret formulas/processes, or
industrial, commercial or scientific equipment/experience.
d. Exempt if paid to the government.
e. Exempt for approved royalties.
f. Lower rate or exempt for industrial royalties in accordance with domestic laws.
g. Royalties derived from Singapore are subject to a final tax of 10%.
Chile - Exempt
Note: 1) This treaty continues to apply to income not covered under the comprehensive treaty (see page 49).
2) Only the Protocol to this treaty continues to apply after the comprehensive treaty came into force (see page 50).
52
Due Dates
Due Date for
Type of Filing Form Designation Due Date for Filing Payment of Tax
• Company group relief application Form GR-A/GR-B By due date for Form Not applicable.
C filing.
• Individual election to carry back or Election Form for As per due date of tax Not applicable.
transfer to spouse unabsorbed Individuals for return.
capital allowances, trade losses Carry-Back of
and donations Capital
Allowances and
Trade Losses
• Return of employee'
s remuneration IR8A/8S By 1 March. Not applicable.
• Notification of cessation of Form IR21 One month before the Per Clearance
employment of an individual who is date of cessation of Directive. Employer
not a citizen or SPR employment. is required to
withhold all monies
until tax clearance is
issued.
• Employer' s notification of CPF Form CPF 91 or Within 14 days of Due date for filing.
Contribution, Skills Development e-submission month end when
Levy and Foreign Workers Levy payment is due.
due to CPF Board
53
Due Dates (continued)
Due Date for
Type of Filing Form Designation Due Date for Filing Payment of Tax
• Directors'remuneration
Form IR37
• Certain distribution by approved
unit trusts
• Prescribed accounting period GST F5 Within 1 month from Within 1 month from
− 3 months (standard) end of prescribed end of prescribed
− 1 month (optional) accounting period. accounting period or
on 15th of the month
following the due date
of Return if under
GIRO.
54
Due Dates (continued)
Due Date of Payment
Type of Filing Form Designation Due Date of Filing of Tax
55
Your PricewaterhouseCoopers Contacts
Tax Partners
Corporate Tax
Paula Eastwood [email protected] 65 6236 3648
Personal Tax
James Clemence [email protected] 65 6236 3948
8 Cross Street, #17-00 PWC Building, Singapore 048424 · Tel 65 6236 3388 · Fax 65 6236 3715
These notes are designed to keep clients up-to-date with tax developments. They are of a general nature only and are not
intended to be comprehensive. Readers are therefore advised that before acting on any matter arising from these notes, they
should discuss their particular situation with us.
No liability can be accepted for any action taken as result of reading the notes without prior consultation with regard to all
relevant factors.
Co.Reg.No.: 52-871777-0
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Notes:
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