Everything You Need To Know About Tax in Singapore (By PWC)

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Tax Facts & Figures*

2008 Singapore
(Incorporating 2008 Budget Proposals)

*connected thinking pwc


Singapore
Tax Facts & Figures 2008
(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.

About PricewaterhouseCoopers
The firms of the PricewaterhouseCoopers (www.pwc.com) global network provide
industry-focused assurance, tax and advisory services to build public trust and
enhance value for its clients and their stakeholders. More than 146,000 people in
150 countries, including more than 1,800 from Singapore, across our network
share their thinking, experience and solutions to develop fresh perspectives and
practical advice.

"PricewaterhouseCoopers" refers to the network of member firms of


PricewaterhouseCoopers International Limited, each of which is a separate and
independent legal entity.

This book is issued to clients and potential clients who have requested for a copy.

Copyright @ 2008 by PricewaterhouseCoopers Singapore


All rights reserved.
MICA (P) 002/05/2008
Contents

Individual Income Tax


• Basis of Taxation 1
• Residence 1
• Individual Income Tax Rates 2
• Tax Exemptions/Relief for Individuals 3
• Not Ordinarily Resident (NOR) Scheme 3
• Resident Taxpayer’s Personal Reliefs 4
• Tax Treatment of Employment Fringe Benefits 7

Employer’s Obligations
• Central Provident Fund Contributions 10
• Skills Development Levy 11

Estate Duty 11

Partnerships, Trusts, Estates, Charities and Mutual Concerns 12

Corporate Income Tax Rates


• Corporate Tax 13
• Withholding Tax 13

Other Tax Rates


• Goods and Services Tax 14
• Capital Gains Tax 14

Stamp Duties 14

Capital Allowances 15

Tax Incentives 16

Special Tax Deductions 46

Non-Fiscal Incentives 48

Transfer Pricing Guidelines 48

Double Taxation Agreements 49

Due Dates 53

Your PricewaterhouseCoopers Contacts 56


Individual Income Tax

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:

• resides in Singapore, except for temporary absences; or

• 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.

As a concession, an individual may also be treated as resident in Singapore if he:

• 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 $

On the first 20,000 0.00 0.00


On the next 10,000 3.50 350.00

On the first 30,000 350.00


On the next 10,000 5.50 550.00

On the first 40,000 900.00


On the next 40,000 8.50 3,400.00

On the first 80,000 4,300.00


On the next 80,000 14.00 11,200.00

On the first 160,000 15,500.00


On the next 160,000 17.00 27,200.00

On the first 320,000 42,700.00

On income above 320,000 20.00

Non-Resident Rates
Type of Income %

Director'
s remuneration 20

Entertainer'
s professional income 15

Other professional income (note 1) 15

Employee'
s remuneration 15
(However, where the tax calculated on resident rates is higher, the resident rates are
used)

Short-term employee's remuneration (note 2) Nil


(Not more than 60 days)

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.

− foreign-sourced income received by resident individuals (except through a partnership or business in


Singapore) and by non-resident individuals.

− Singapore-sourced investment income from certain financial instruments derived by resident and
non-resident individuals.

• Tax relief is available to the following individuals:

− one who is not resident in, but is a citizen of Singapore; and

− 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 assessable income Tax payable at graduated rates


X (Part C, Second Schedule)
Aggregate/world income

Singapore citizens and permanent residents who have worked for at least 6 months overseas in any
calendar year could be considered as non-resident.

Not Ordinarily Resident (NOR) Scheme


A Singaporean, Singapore permanent resident (SPR) or foreigner may qualify for NOR status for a 5-year
period if he:

• 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;

• exemption of employer' s contributions to non-mandatory overseas social security schemes/pension funds


(only available to non-Singapore citizens/non-SPRs); and

• 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

Earned Income Relief Below 55 yrs 55 to 59 yrs Over 59 yrs

Normal $1,000 $3,000 $4,000


(or earned income if less)
Handicapped $2,000 $5,000 $6,000

Dependants Relief (note 1)


Wife relief $2,000

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)

Child relief See page 6

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.

Provident Fund/Life Insurance Relief


• Central Provident Fund (CPF) contributions Statutory rate
(see page 10)

• 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.

• Life insurance premium paid on the taxpayer or his wife'


s life Lower of 7% of the capital sum
assurance policies. assured or $5,000 less CPF
contributions

4
Resident Taxpayer's Personal Reliefs (continued)

Relief for Supplementary Retirement Scheme (SRS)


SRS contributions by employee and/or employer, subject to
capping rules:

- Singapore citizens and permanent residents 15% of computed sum

- Foreigners 35% of computed sum

NSman Relief
Claimable by: Active Non-active

- NSman $3,000 $1,500

- NS Key Appointment Holders $5,000 $3,500

- Parent $750 $750

- Wife $750 $750

Foreign Domestic Worker Levy Relief


Twice the amount of the monthly levy of $295 or $200 (reduced to $265 or $170 from 1 July 2007) paid during
the basis period for 1 maid is claimable by a married woman against her earned income. This includes one
who is separated from her husband, a divorcee or widow who is claiming child relief.

Course Fees Relief


Relief of up to $3,500 per annum is available on course fees for courses of study leading to academic,
professional or vocational qualifications, and registration fees for seminars and conferences related to the
individual’s existing business or employment. Courses that are not directly related to the individual's current
profession would also qualify provided the courses result in a career switch to a relevant job within 2 years.

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.

One-off Personal Tax Rebate (YA 2008)


A one-off personal tax rebate of 20% of tax payable (after tax credit and other reliefs, but before other tax
rebates and tax deducted at source) is available for YA 2008, subject to a cap of $2,000.

5
Resident Taxpayer's Personal Reliefs (continued)

Child Relief/Marriage & Parenthood Reliefs and Rebates


• Qualifying Child Relief (QCR) (note 1 & 2) – Claimable by either parent or shared between both parents.

1st to 3rd child $2,000 per child


th
4 child born on or after 1 January 1988 $2,000

• 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.

1st child Nil


nd
2 child $10,000
rd th
3 & 4 child $20,000 per child

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.

1st child 5% of earned income


nd
2 child 15% of earned income
rd
3 child 20% of earned income
th
4 child born on or after 1987 or a child 25% of earned income
adopted on or after 1 January 2004

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

Summary of Main Fringe Benefits


Benefit Assessable Income to Taxpayer

Accommodation:

• Company-provided housing • Lower of 10% of total remuneration (including other benefits) or


annual value of premises, less any rent paid by the taxpayer
(note).

• Hotel accommodation • 2% of basic salary for the period plus:


i) $250 per month per adult (includes child above 20 years of
age);
ii) $100 per month per child between 8 and 20 years of age;
iii) $50 per month per child between 3 and 7 years of age; and
iv) $25 per month per child under 3 years of age.

• Housing allowance • Actual cost to employer.

• Water, electricity & telephone bills, • Actual cost to employer.


clothing, servants, etc

• Household furniture & fittings • Nominal rates predetermined by IRAS.

Overseas travel:

• Relocation expenses to and from • Not taxable.


Singapore

• Home leave passage • Actual amount paid by employer for Singapore citizen and SPR
employees.

• 20% of home leave passage cost paid by employer for other


foreign employees. Concession restricted to:
i) one home trip for taxpayer and spouse; and
ii) two home trips for each child.

• Not taxable if employed by certain Overseas Headquarter (OHQ)


or pioneer companies.

• Per diem allowance for business • Amount in excess of acceptable rate published by IRAS (annual
trips rate for each country varies).

• Per diem reimbursement of • Not taxable.


business expenses

Transport:

• Transport allowance • Total amount paid by employer.

• 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

• Shuttle bus service • Not taxable.

Note: Variations exist for directors.

7
Tax Treatment of Employment Fringe Benefits (continued)

Summary of Main Fringe Benefits


Benefit Assessable Income to Taxpayer

Income tax • Actual amount paid by employer, grossed up.

Loans:

• Interest-free or subsidised loans • Generally not taxable (note 1 & 2).


provided by employer

• Interest subsidy for commercial • Actual cost to employer.


loan taken up by employee

• Waiver of principal sum • Taxable.

One-off lump-sum payments:

• Restrictive covenants • Generally not taxable.

• Compensation for loss of office • Generally not taxable.

• Compensation for death or • Not taxable.


permanent disablement

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.

• Under the Qualified Employee Equity-based Remuneration


Scheme, tax may be paid over 5 years, but with interest (note 2).

Insurance and medical benefits:

• 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

Note: 1) Variations exist for directors.


2) Conditions apply.

8
Tax Treatment of Employment Fringe Benefits (continued)

Summary of Main Fringe Benefits


Benefit Assessable Income to Taxpayer

Retirement benefits:

• Pensions and retirement benefit • Taxable unless:


i) benefits were accrued in approved pension funds up to 31
December 1992; or
ii) unapproved retirement benefit plans satisfy certain criteria.

• Supplementary Retirement • Employers are only allowed to contribute to employees’ SRS


Scheme (SRS) accounts up to prescribed limits w.e.f. 1 October 2008. The
contributions are taxable but a corresponding relief is available
(see page 5).

• Upon withdrawal:

− 50% of amount withdrawn:


i) on or after prescribed retirement age;
ii) on medical grounds;
iii) on death; and
iv) by foreigners who had maintained his/her SRS account for
at least 10 years.

− 100% of withdrawn amount in situations other than those


mentioned above. Penalties apply for early withdrawal.

• Withholding tax at prevailing non-resident tax rate imposed on all


withdrawals by foreigners and SPRs.

• 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.

• Employer’s contributions to • Taxable unless contributions are compulsory, made to overseas


provident/pension fund outside funds operated by the home country government and deduction
Singapore is not claimed by a Singapore company.

Meals, entertainment, social and


recreational benefits:

• Club dues for business • Not taxable.

• Meal/entertainment allowance • Total amount paid by employer.

• Not taxable if meal allowance/reimbursement is for working


overtime and policy is generally available to all staff.

• Benefits to promote creativity and • Not taxable.


innovation or to encourage
upgrading of skills and knowledge
building

• 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)

Summary of Main Fringe Benefits


Benefit Assessable Income to Taxpayer

• 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).

• Not taxable if for bereavement.

Other benefits:

• Laptops, palmtops and mobile • Not taxable.


phones for business purposes

• Staff uniform • Not taxable.

• School fees • Actual cost to employer.

• Childcare benefits • Not taxable if the child attends a licensed childcare centre.

Employer’s Obligations

Central Provident Fund (CPF) Contributions


The CPF is essentially a savings scheme to provide for employees in their old age. By law, all employers are
required to make monthly CPF contributions for Singaporean and SPR employees working in Singapore, part
of which may be recovered from the employees’ wages.

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

• additional wages (e.g. year-end bonus), subject to a ceiling of:

- 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)

Skills Development Levy


Employers are required to contribute 1% of the salary of employees earning not more than $2,000 per month
to the Skills Development Fund (SDF). With effect from 1 October 2008, the contribution rate will be reduced
to 0.25%, but employers must contribute the levy on the first $4,500 of the gross remuneration of all
employees.

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:

Principal Value of Estate $ Rate of Duty %

On the first 12,000,000 5

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:

For successive deaths occurring within Estate duty relief

< 6 months 100%

> 6 to 12 months 75%

> 12 to 18 months 50%

>18 to 24 months 25%

> 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.

Business • Treated as a company. Prevailing corporate


Trust tax rate.

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 %

• Normal rate (note 1) 18

• 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.

• Concessionary rates – Incentive Companies (see page 16). Exempt to 15

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

ii) rent or other payments for the use of movable property 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)

v) professional service fees (note 3) 15

vi) technical fees 18

vii) management fees 18

viii) director'
s remuneration 20

ix) charter fees 1 to 3

x) sale of real properties by real property traders 15

xi) real estate investment trust (REIT) distributions to non-individuals out of certain 10
income

xii) payments to public entertainers 15

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) %

On supply of goods and services in Singapore 7

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

Capital Gains Tax

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.

Stamp Duties (Selected Transactions)


Purchase or Gift of Immovable Property $

On purchase price or market value, whichever is higher:

− every $100 or part thereof of the first $180,000 1.00


− every $100 or part thereof of the next $180,000 2.00
− thereafter, every $100 or part thereof 3.00

Transfer or Gift of Shares $

On purchase price or net asset value, whichever is higher:

− every $100 or part thereof 0.20

Reliefs/Remissions

Section 15 relief is available (subject to conditions) for:


i) transfers of immovable properties and shares, as well as financial institutions'mortgages with their
customers, in reconstruction or amalgamation of companies;
ii) transfers of immovable properties and shares, as well as financial institutions'mortgages with their
customers, between associated companies, business trusts, statutory boards, unlimited companies and
limited liability partnerships where all the partners are companies; and
iii) conversion of a firm to a limited liability partnership.

Stamp duty remission is available for:


i) sales of immovable properties into REITs listed or to be listed on the Singapore Exchange;
ii) qualifying Islamic financing arrangements;
iii) transfer of assets into an Approved Special Purpose Vehicle (see page 27) and
iv) transfer of qualifying infrastructure projects or assets into entities listed or to be listed on the Singapore
Exchange.

14
Capital Allowances
Categories Capital
Allowance
%

• Plant and machinery

− 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 for the purposes of a trade, business or profession (prior to YA 33


2009, this excluded motor cars, motor cycles and light goods vehicles)

− 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

• Industrial buildings and structures

− 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

• Approved know-how, patent rights and intellectual property rights 20

• Approved cost-sharing agreements 100 (note 2)

• Indefeasible right to use any international telecommunications submarine cable system


(IRU) (note 3)

– annual allowance Varies (note 4)

• Fixtures, fittings and installations See page 48

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

Page Page Page


• Pioneer Enterprise 17 • Investment Allowance (IA) for Flagship • Global Trader Programme (GTP) 25
• Approved Royalty Incentive (ARI) 17 Concept Projects 18 • Approved Cyber Trader (ACT) 26
• Approved Foreign Loan Incentive (AFL) 17 • Pioneer Service Companies 18
• Export of Services 19
• Expansion Incentive for Partnerships
(EIP) 19
• Headquarters (HQ) Programme 20
• Approved International Shipping (AIS)
Enterprise 21
• Approved Shipping & Logistics (ASL)
Scheme 23
• Offshore Shipping 23
• Freight Uplift 24
• Approved Mega Events 24
• International Arbitration 24
• Not-for-Profit Organisations (NPOs) 24

• Development and Expansion Incentive (DEI) 17


• Investment Allowance (IA) 17
• Research & Development (R&D) Incentive for Start-up Enterprise (RISE) 18

INVESTMENTS FINANCE

LOCAL OVERSEAS

Page Page Page


• Enterprise Investment Incentive (EII) 26 • Foreign Trust 32 • Financial Sector Incentive (FSI)
• Approved Investment Companies 27 • Foreign Charitable Purpose Trusts 32 Scheme 34
• Asset Securitisation 27 • Approved Venture Company 33 • Start-up Fund Managers 36
• Maritime Finance Incentive (MFI) 28 • Overseas Enterprise Incentive (OEI) 33 • Securities Borrowing and Lending
(SBL) 37
• Foreign Investors 29
• Futures Members of the Singapore
• Resident Funds 29 Exchange (SGX) 37
• Approved CPF Unit Trust 30 • Offshore Commodity Futures Trading 37
• Designated Unit Trust (DUT) 30 • Commodities Derivatives Market
• Locally Administered Trust 31 Incentive 38
• Approved Family-owned Investment • Over-the-Counter (OTC) Financial
Holding Company (FIHC) 32 Derivatives 39
• General Clearing Member of OTC
Derivatives 39
• Finance and Treasury Centre (FTC) 39
• Approved Trustee Company (ATC) 40
• Insurance 40
• Approved Insurance/Reinsurance
Brokers 42
• Offshore Leasing 42
• Aircraft Leasing Scheme (ALS) 42
• High Value-Added Processing Services
Supporting Financial Activities 43
• Bond Market Incentives 43
• Structured Products 44
• Infrastructure Project Finance 45

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.

Most projects can be considered


unless products are already
manufactured locally without tax
incentives.

• Approved EDB Technology or know-how Exemption or For the duration


Royalty transferred must be more reduced withholding of the
Incentive advanced than the prevailing tax on royalties or agreement.
(ARI) industry average. technical assistance
fees payable to
non-residents.

• 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.

• Investment EDB i) Companies engaged in Tax exemption on Indefinite until


Allowance (IA) qualifying activities and the chargeable income allowance is
asset contributes to greater equal to approved used up.
efficiency or introduces new percentage not
technology to the industry. exceeding 100% of Projects for the
capital expenditure provision of
ii) The asset must be used in incurred on the maintenance,
Singapore (except for projects following qualifying repair and
relating to space satellites and assets: overhaul
aircraft). services to
a) plant and aircraft must be
iii) Investment must be made machinery approved
within the stipulated qualifying before 9
period which should not exceed b) factory building September
5 years (or 10 years for projects 2009.
for promotion of tourist c) acquisition of
industry) from Investment Day, know-how or
unless the asset is on patent rights
hire-purchase and acquired on
or after 15 February 2007.

iv) No minimum investment


requirement.

17
Tax Incentives – Manufacturing/Services (continued)
Type ++ Requirements Incentives Relief Period

v) The asset cannot be disposed


of within the qualifying period
and for 2 years thereafter
without approval.

• R&D # Start-up companies must: Conversion of up to First 3 years of


Incentive for $225,000 of tax assessment
Start-up i) be incorporated and resident in losses at a 9% rate to from
Enterprise Singapore with any of their first cash grant of up to incorporation
(RISE) 3 years of assessment falling $20,250. falling within YA
within YA 2009 to YA 2013. 2009 to YA
2013.
ii) have not more than 20
shareholders, all of whom are
individuals, or at least 1 of
whom is an individual holding
at least 10% of the total number
of issued ordinary shares.

iii) never have been in a


tax-paying position.

iv) incur at least $150,000


qualifying R&D expenditure
undertaking in-house R&D in
Singapore in the basis period
relating to the year of
assessment of claim.

v) have on-going R&D activities at


the time of claim.

Further details to be released.

• IA for STB i) Investments in flagship concept Tax exemption on For projects


Flagship projects in retail, food & chargeable income approved from
Concept beverage and entertainment equal to an approved 1 April 2005 to
Projects that are first of their kind in percentage of 30% or 31 March 2010.
South East Asia, have wide 50% of the capital
international appeal and expenditure incurred Indefinite until
enhance Singapore’s on: allowance is
attractiveness as a tourist used up.
destination. a) specialised or
high-tech
ii) Projects must be completed equipment;
within 2 years of approval.
b) leasehold
improvement
items.

• 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

• Export of EDB i) Companies must be engaged Exemption of 90% of Up to 10 years


Services in providing prescribed incremental export with provision for
services which relate to services income. extension up to a
overseas projects for maximum total
non-residents. relief period of
20 years.
ii) Minimum export level of 20% of
total revenue and commitment
in terms of skilled manpower
and fixed asset investments
expected.

• Expansion EDB i) Partnership in Singapore Exemption of 50% of 5 years.


Incentive for providing audit, accounting or incremental qualifying
Partnerships legal services, with at least overseas income.
(EIP) 50% equity stake held by
Singapore tax residents.

ii) Well-established in the


industry, attained critical size
(equity, assets, employees,
business share, etc).

iii) Establish a Centre of


Competence, which should be
the nerve centre in terms of
providing management and
control, R&D, training and
advice on a regional scale, with
at least 5 professionals by the
end of year 3 of the incentive
period.

iv) Personnel for incentivised


operations are based in
Singapore.

v) Employ at least 10 additional


professionals by the end of
year 5 of the incentive period.

vi) Incur at least an additional $2


million in annual business
spending in Singapore by the
end of year 3 of the incentive
period.

19
Tax Incentives – Services (continued)
Type ++ Requirements Incentives Relief Period

• Headquarters EDB General qualifying criteria:


(HQ)
Programme i) Well-established in the
industry, attained critical size
(equity, assets, employees,
business share, etc).

ii) Nerve centre of organisation


reporting structure at senior
management levels.

iii) Clear-cut management and


control over its principal
activities.

iv) Substantial level of HQ


activities in Singapore.

v) Personnel for HQ operations


are based in Singapore.

− Regional The company must: 15% tax on 3 years with


Headquarters incremental provision for
(RHQ) a) increase its paid-up capital to at qualifying income. extension for an
Award least $0.2 million and $0.5 additional 2
million at the end of year 1 and years.
year 3 of the incentive period
respectively;

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;

c) employ at least 75% skilled


staff throughout the incentive
period;

d) employ at least 10 additional


professionals based in
Singapore by the end of year 3
of the incentive period;

e) incur an average remuneration


per worker of $100,000 per
annum for the top 5 executive
designations by the end of year
3 of the incentive period;

20
Tax Incentives – Services (continued)
Type ++ Requirements Incentives Relief Period

f) incur at least an additional $2


million in annual business
spending in Singapore by the
end of year 3 of the incentive
period; and

g) incur at least an additional $3


million in business spending
cumulatively for the entire
incentive period.

− International Companies that commit to Tax rates as low as 5 to 20 years.


Headquarters substantially exceed the minimum 0% on qualifying
(IHQ) Award criteria for the RHQ Award. income and other
incentives,
customised based on
commitment level
and considered in
discussion with EDB.

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

ii) from the date the company is


granted approved holding
company status to the date of
disposal of shares.

• 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

iii) have substantial operations c) income from


and possess a team of key the operation
personnel in Singapore to of any vessels
control and manage the fleet used for
(the manpower requirement is offshore oil
lifted for floating production, and gas
storage and offloading (FPSO) activities;
vessels and floating storage
and offloading (FSO) vessels). d) proceeds from 10 years w.e.f.
sale of YA 2005.
vessels;

e) proceeds from Details to be


sale of released.
vessels in a
sale and
leaseback
arrangement;

f) proceeds from Details to be


the sale of released.
shares in a
special
purpose
company
which holds
ships; and

g) foreign Indefinite.
exchange
gains and
gains from risk
management
activities.

ii) Withholding tax


exemptions on:

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.

ii) have concrete business plans Tax exemption on


demonstrating their dividend income
commitment to embark on received from
expansionary programmes approved network of
from Singapore; companies.

iii) generate incremental business


spending in Singapore by the
end of the incentive period; and

iv) use Singapore for their logistics


and freight management
activities in the region.

• Offshore # Companies owning or operating:


Shipping
i) Singapore-registered vessels i) Tax exemption Indefinite.
in international traffic (w.e.f. YA on:
2007, this includes the use of
vessels as dredgers, seismic a) qualifying
ships or for offshore oil or gas shipping and
activity). charter hire
income

b) proceeds from 10 years w.e.f.


the sale of YA 2005.
vessels;

c) proceeds from Details to be


sale of released.
vessels in a
sale and
leaseback
arrangement;

d) proceeds from Details to be


the sale of released.
shares in a
special
purpose
company
which holds
ships; and

23
Tax Incentives – Services (continued)
Type ++ Requirements Incentives Relief Period

e) foreign Indefinite.
exchange and
gains from risk
management
activities.

ii) foreign-registered vessels in ii) Tax exemption on Indefinite.


international traffic. qualifying shipping
income.

• 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.

• International EDB Approved law practice providing Tax exemption on Up to 5 years,


Arbitration legal services in connection with 50% of incremental with window
international arbitration hearings qualifying profits period for
held in Singapore which: (excludes income from approval from 1
outsourced arbitration July 2007 to 30
i) maintains a minimum of 3 work). June 2012.
full-time equivalent lawyers
engaged in international
arbitration work in Singapore
throughout the incentive period;
and

ii) meets an agreed annual


qualifying income target.

• Not-for-Profit EDB/ NPO with a regional or international Tax exemption. Up to 10 years


Organisations MAS focus and strong linkages to key with window
(NPOs) industry clusters and which period for
contributes to the economic approval from
development of Singapore. 15 February
2007 to 14
February 2017.
Provision for
extension for
NPOs approved
during this
period.

24
Tax Incentives – Trade
Type ++ Requirements Incentives Relief Period

• Global IES i) Companies carrying on the 5% or 10% tax on 5 years with


Trader business of international qualifying income, provision for
Programme trading of commodities futures, depending on extension.
(GTP) including petroleum and company' s
petroleum products, and commitment levels.
carbon credits which:

a) use Singapore as nerve


centres for their principal
offshore trading activities in
the region and for business
activities and support
functions;

b) are established with


worldwide networks and
good track records;

c) have significant amounts of


directly attributable total
business spending in
Singapore per annum and
substantial offshore
physical trading turnover on
a principal basis;

d) employ a commensurate
number of experienced
trading professionals in
Singapore;

e) contribute to manpower
training and development of
trading expertise in
Singapore;

f) make significant use of


Singapore' s banking,
financial and other business
services; and

g) support and make use of


Singapore' s trade
infrastructure.

ii) LNG trading (w.e.f. 24 May 5% tax on qualifying 10 years.


2007). income.

iii) High-growth, medium-sized 10% tax on qualifying 3 years.


trading companies. income.

25
Tax Incentives – Trade (continued)/Investments
Type ++ Requirements Incentives Relief Period

• Approved IES Company must: 10% tax on 5 years.


Cyber Trader incremental
(ACT) i) conduct its principal qualifying income
e-commerce activities and from qualifying
handle a whole range of electronic commerce
business activities and support transactions.
functions in Singapore;
Investment
ii) incur a significant amount of allowance of up to
directly attributable business 50% of cost of
spending in Singapore; qualifying new fixed
capital expenditure.
iii) contribute to manpower
training and development in
Singapore; and

iv) make significant use of


Singapore’s business services.

• Enterprise SPRING i) Investor may be an individual Deduction for 5 years for


Investment or a company. investors of losses of start-ups
Incentive (EII) up to $3 million approved before
ii) Qualifying start-up companies incurred on disposal 1 September
must be: of qualifying 2009.
shares/liquidation of
a) unlisted in their initial years the start-up company.
of existence with paid-up
capital of at least $10,000;

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.

iii) Investments must be:

a) in the form of a purchase of


new ordinary share capital
in the start-up and not
replacement capital or debt
instruments;

b) without any condition that


would eliminate the
investor'
s risk;

c) at least $1,000 per


investment; and

26
Tax Incentives – Investments (continued)
Type ++ Requirements Incentives Relief Period

d) issued and acquired by the


investor during the
start-up's approved status
and sold between the start
of the second year and the
end of the sixth year from
the date of purchase of the
shares.

iv) Technopreneur companies


supported under the Innovation
Commercialisation Scheme
(ICS) automatically qualify.

v) Overseas start-ups may be As above, but


approved on a case-by-case confined to
basis provided that there is a Singaporean/SPR
significant link for Singapore to investors.
enjoy the economic spin-offs
from their activities.

• Approved MOF Companies whose business is to Proportion of gains Indefinite.


Investment invest in securities and the subject to tax based
Companies principal part of their income is on holding period of
derived therefrom. investments.

• 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

v) have all its issued shares held in iv) Stamp duty


trust for the benefit of 1 or more remission for
organisations or institutions that transfer of
are established for charitable, specified assets
benevolent or philanthropic into the ASPV.
purposes; the trust must be
administered by a trust
company in Singapore;

vi) transact any cross-currency or


interest rate swaps with a swap
counterparty in Singapore;

vii) be tax resident in Singapore;

viii)ensure that all debt securities


issued are qualifying debt
securities and the size of the
issuances is not less than $20
million. W.e.f. 16 February
2008, the ASPV is allowed to
issue non-qualifying debt
securities; and

ix) not have 30% or more of the


issued debt securities
beneficially held or funded by
the originator.

• 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.

ii) ASIV that is a company Tax exemption on Entire life of


incorporated and tax resident in qualifying lease qualifying vessel
Singapore or a registered income. acquired during
business trust engaged in the the 10-year
chartering or finance leasing, for incentive period.
operation in international traffic,
of:

a) ships to non-tax residents of


Singapore; and

b) Singapore-registered ships
or foreign-registered ships
to AIS companies.

28
Tax Incentives – Investments (continued)
Type ++ Requirements Incentives Relief Period

iii) Approved Container Investment 10% tax on qualifying Income derived


Management Company (ACIM) management income. w.e.f. 1 April
managing an Approved 2008, with
Container Investment window
Enterprise (ACIE). approval period
from 1 April
2008 to 28
February 2011.

iv) ACIE engaged in operating or 5% or 10% tax on Entire life of


finance leasing of sea qualifying lease qualifying
containers to offshore and income, depending on containers
onshore lessees. local business acquired during
spending and the 10-year
v) Partnerships are eligible for the headcount incentive period.
above w.e.f. from 1 April 2008. commitment levels. Window
approval period
Further details to be released. from 1 April
2008 to 28
February 2011.

• Foreign # The fund must be: Tax exemption on Indefinite, w.e.f.


Investors qualifying income 1 September
i) an account of an individual who derived by qualifying 2007.
is not a citizen or resident of investors which
Singapore, or a company/trust include:
not wholly owned by investors in
Singapore. The company or i) individuals;
trustee must be a non-resident
without any permanent ii) non-resident
establishment in Singapore and non-individual
must not carry on business in investors with no
Singapore. permanent
establishment in
ii) managed by a fund manager in Singapore; and
Singapore that is a company
holding, or exempted from iii) any investor that
holding, a capital markets beneficially owns
services licence under the not more than 30%
Securities and Futures Act for or 50% of the value
fund management. of the fund, if the
fund has less than,
iii) invested in designated assets. or 10 or more
investors
Investors must be the beneficial respectively.
owners of the funds managed.

• 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

ii) use a Singapore-based fund W.e.f. 1 September


administrator and be managed 2007, tax exemption
directly by a fund management for qualifying income
company in Singapore holding, derived by qualifying
or exempted from holding, a investors which
capital markets services licence include:
under the Securities and
Futures Act for fund i) individuals;
management; and
ii) non-resident
iii) incur expenses of at least non-individual
$200,000 in each financial year. investors with no
permanent
establishment in
Singapore; and

iii) any investor that


beneficially owns
not more than 30%
or 50% of the value
of the fund, if the
fund has less than,
or 10 or more
investors
respectively.

• 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.

Tax exemption for


Singapore-resident
unit holders who
invest using cash.

• Designated IRAS A unit trust: Tax exemption for Indefinite.


Unit Trust DUT for income and
(DUT) i) that is a collective investment gains from designated
scheme (CIS) that is authorised investments.
under section 286 of the
Securities and Futures Act and Tax exemption for
is open to the public for individual unit holders
subscription, authorised as a and foreign investors
Restricted Authorised Scheme for DUT distributions.
(RAS) or exempt from
authorisation;

ii) whose trustee is tax resident in


Singapore;

iii) not a REIT/property trust that


invests directly in Singapore
real estate;

30
Tax Incentives – Investments (continued)
Type ++ Requirements Incentives Relief Period

iv) whose investment/fund


manager is incorporated in
Singapore and holds a valid
licence to carry out fund
management activity or is
exempt from holding such a
licence;

v) with not more than 50% of its


investments beneficially held by
related parties of the
investment/fund manager;

vi) whose investors do not have


day-to-day control over the
management of the
investments, the right to be
consulted or to give directions in
respect of such management,
or any control or influence over
the distribution policy of the unit
trust; and

vii) whose assets were not


transferred from any company
in Singapore whose income
from such assets would not
have been tax-exempt.

• Locally MAS A trust: Tax exemption for the Indefinite.


Administered trust and its qualifying
Trust i) created in writing; underlying holding
companies for
ii) where all settlors are specified
individuals; Singapore-sourced
and foreign-sourced
iii) where all beneficiaries are investment income
either individuals or charities; derived/received on or
after 17 February
iv) that is not a trust whereby the 2006.
beneficiaries are settlors of the
trust; Tax exemption for
beneficiaries on
v) where the assets held under the distributions out of
trust were not transferred from qualifying trust
any business carried on in income.
Singapore in relation to
investments by any person, and
income derived by that person
from that business in Singapore
was not or would not be, exempt
from tax; and

vi) that is administered by a trustee


company in Singapore.

31
Tax Incentives – Investments (continued)
Type ++ Requirements Incentives Relief Period

• Approved MAS A qualifying family-owned Tax exemption for 5 years from 1


Family- investment holding company. Singapore-sourced April 2008 to 31
owned investment income March 2013.
Investment Further details to be released. and foreign-sourced
Holding income mirroring the
Company tax exemption for
(FIHC) individuals (see page
3).

• 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.

i) individuals who are neither Tax exemption for


citizens of Singapore nor beneficiaries on
resident in Singapore; distributions out of
qualifying trust
ii) foreign companies; income.

iii) trustees of other foreign trusts;

iv) foreign accounts of


philanthropic purpose trusts; or

v) persons neither resident in


Singapore nor constituted or
registered under any written
laws in Singapore.

• Foreign # Foreign accounts of a charitable Tax exemption on: Indefinite.


Charitable purpose trust created for public
Purpose benefit and eligible holding a) specified income
Trusts companies. derived from
designated
Foreign accounts are sections of investments by
the trust whose assets/funds are eligible holding
injected by a settlor who is: companies; and

i) an individual and is neither a b) the following


citizen of Singapore nor income derived by
resident in Singapore; a foreign account
of a charitable
ii) a foreign company or trust; purpose trust
administered by a
iii) another foreign account of a trustee company:
charitable purpose trust; or
i) dividends paid
iv) any other person neither or payable by
resident in Singapore nor eligible holding
constituted or registered under companies
any written laws in Singapore. from the
income in
paragraph (a);
and

32
Tax Incentives – Investments (continued)
Type ++ Requirements Incentives Relief Period

Eligible holding companies: ii) specified


income derived
i) are companies incorporated from
outside Singapore and designated
wholly-owned by the trustees of investments.
the trust or by their nominee;

ii) are set up to hold assets of a


philanthropic purpose trust;

iii) are engaged solely in trading or


making investments for the
purpose of the trust; and

iv) do not claim any foreign tax


credit in Singapore.

• 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.

• Overseas IES i) Companies must be Tax exemption on: Up to 10 years.


Enterprise incorporated and tax resident in
Incentive Singapore with substantial a) dividends from
(OEI) operations in Singapore, and be qualifying
at least 50% owned by overseas
Singapore citizens or investments; and
permanent residents.
b) royalties, interest
ii) Qualifying projects must on shareholder
generate economic spin-offs loans, incremental
(expand Singapore operations, income from the
provide technology or market provision of
access, technology transfer, support services
support for flagship projects, (project
etc.) for Singapore. management,
technical support,
33
Tax Incentives – Investments (continued)/Finance
Type ++ Requirements Incentives Relief Period

etc.) performed
within or outside
Singapore and
overseas project
income relating to
approved
qualifying projects.

• Financial MAS For new applicants, the Unless


Sector requirements for the respective otherwise
Incentive awards are provided below. For specified below,
(FSI) Scheme renewal of existing awards, 5 to 10 years,
incremental commitments to with provision for
Singapore and other qualitative 5 years
factors will be taken into extension.
consideration. Applications
must be made
− Standard-tier Financial institutions must employ 10% tax on before 31
Awards at least 5 professional staff in any of incremental income December 2013.
(FSI-ST) the qualifying activities in above a qualifying
Singapore. Other qualitative base (QB) derived
factors will also be taken into from qualifying
consideration. activities provided
there is at least 1
Financial institutions that transited professional staff
from the Asian Currency Unit engaged in the
(ACU) tax incentive to this scheme respective categories
on 1 January 2004 must employ at of activities. The QB is
least 6 professional staff in not imposed for
qualifying activities in order to headquarters
qualify for renewal of their awards. services, fund
management or
i) Fund Financial institutions engaged only investment advisory
Manager in fund management or investment activities.
(FSI-FM) advisory services must employ at
least 3 professional staff in
qualifying activities in Singapore.

From 1 September 2007, qualifying


fund managers of qualifying foreign
funds and resident funds are those
managing funds in which all
investors qualify for tax exemption.

ii) Headquarter i) Financial institutions previously Up to the expiry


Services enjoying the Operational of the existing
(FSI-HQ) Headquarters incentive. awards.

ii) New applicants which:

a) perform at least 3 qualifying


headquarters services;

b) maintain at least 4
professional staff in
headquarters services;

34
Tax Incentives – Finance (continued)
Type ++ Requirements Incentives Relief Period

c) incur annual total business


spending of at least $2
million; and

d) service at least 2 network


companies outside
Singapore.

− Enhanced-tier MAS 5% tax on income


Awards derived from qualifying
activities.

i) Debt Capital This award merges the Bond Market


Market (FSI-BM), Credit Facilities
(FSI-DCM) Syndication (FSI-CFS) and Project
Finance (FSI-PF) awards:

i) A bond market company Additional benefit:


(formerly FSI-BM) must: Debt securities lead
managed by a
a) employ at least 8 professional company with the
staff covering origination, FSI-BM award will be
trading and distribution of granted automatic
debt securities; and qualifying debt
securities status (see
b) demonstrate its degree of Bond Market
expertise in origination and Incentives).
structuring, as well as the
extent of debt sales,
distribution and trading
capabilities in Singapore.

ii) A credit facilities syndication


(formerly FSI-CFS) company
must employ at least 2
professional staff performing any
syndication functions in
Singapore.

iii) A project finance (formerly 5 years.


FSI-PF) company must employ Applications
at least 5 professionals who are must be made
engaged in project finance. on or before 31
December
2011.

ii) Derivatives i) Companies previously enjoying Additional benefit:


Market the Approved Derivatives Trader Withholding tax
(FSI-DM) incentive. exemption for
payments on
ii) New applicants that employ at qualifying derivatives.
least 6 professional staff
covering origination, structuring
and trading activities in relation
to financial derivatives, and
demonstrate the extent to which
the financial derivatives team in
35
Tax Incentives – Finance (continued)
Type ++ Requirements Incentives Relief Period

Singapore has responsibility for


structuring or trading of
derivatives.

iii) Equity Market i) Companies previously enjoying


(FSI-EM) the Equity Capital Market
Intermediary incentive.

ii) New applicants that employ at


least 3 professional staff who
are performing corporate
finance, sales/trading or
research activities in Singapore.

iv) Islamic i) A licensed bank or approved 5 years, with


Finance merchant bank engaged in window
(FSI-IF) Shari’ah-compliant lending and approval period
related activities. from 1 April
2008 to 31
ii) A company holding a capital December
markets services licence for 2013.
fund management under the
Securities and Futures Act or
exempted from holding such a
licence, engaged in
Shari’ah-compliant fund
management and the provision
of investment advisory activities
in relation to funds.

The incremental number of


experienced professionals
significantly involved in qualifying
activities and the applicant’s
business plan will also be taken into
consideration.

• 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;

iii) a non-resident of Singapore;

iv) a foreign branch of a


Singapore-resident company;

v) an approved oil trader (for


transactions in petroleum and
petroleum product futures only);
or

vi) a foreign investor, through an


FSI company.

Companies that are a futures 5% tax on incremental Designated


member of the SGX for at least 3 income from futures that
years and are among the top 20 designated commenced
corporate futures members. This is transactions above. trading on SGX
also extended to corporate during the
members of any securities market period 1 April
maintained by SGX Securities 1994 to 31
Trading Limited that are within the December 2001.
top 20 members, as determined by
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;

ii) another Exchange member;

iii) a non-resident of Singapore; or

iv) a foreign branch of a


Singapore-resident company.

37
Tax Incentives – Finance (continued)
Type ++ Requirements Incentives Relief Period

• Commodities MAS Qualifying financial institutions and 5% concessionary tax Up to 5 years,


Derivatives companies must demonstrate the rate on income from with window
Market extent to which the OTC financial qualifying transactions approval period
Incentive derivatives team in Singapore has in: from 27
responsibility for structuring or February 2004
trading of derivatives and employ: to 26 February
2009.
i) at least 3 professionals covering i) OTC commodity
origination, structuring and derivatives in any
trading activities in relation to currency; or
OTC commodity derivatives; or

ii) employ at least 5 professionals ii) both OTC


covering the above activities in commodity
relation to OTC and derivatives and
exchange-traded commodity exchange-traded
derivatives. commodities.

Qualifying transactions are those


with:

i) a bank or merchant bank that is


an FSI company;

ii) an approved global trading


company;

iii) an approved commodity


derivatives trading company;

iv) a non-resident of Singapore;

v) a foreign branch of a
Singapore-resident company;

vi) a member of the Singapore


Commodity Exchange;

vii) an approved oil trading


company;

viii)an approved international


commodity trading company; or

ix) a petroleum refining or


approved petrochemical
manufacturing company.

38
Tax Incentives – Finance (continued)
Type ++ Requirements Incentives Relief Period

• Over-the- MAS Payments made on qualifying OTC Withholding tax i) Payments


Counter financial derivatives by a financial exemption for due and
(OTC) institution to persons who are payments on payable
Financial neither residents nor permanent qualifying derivatives. during the
Derivatives establishments in Singapore. period from
27 February
2004 to 19
May 2012.

ii) For the entire


duration of
contracts
entered into
during the
period from
15 February
2007 to 19
May 2012.

• General MAS An approved clearing member of a 5% tax on income 5 years, with


Clearing Singapore OTC derivatives derived from the window
Member of clearing facility which: provision of clearing approval period
OTC services in Singapore. from 17
Derivatives i) employs and maintains at least February 2006
3 professionals to undertake to 16 February
OTC derivatives clearing 2011.
services in Singapore; and

ii) provides the OTC derivatives


clearing services using a
Singapore clearing house

Other qualitative factors such as


degree of expertise and scope of
OTC derivatives clearing activities
will be considered.

• Finance and EDB A division or department of a 10% tax on income 5 to 10 years


Treasury company which provides treasury, arising from provision with provision for
Centre (FTC) investment or financial services in of qualifying services extension.
Singapore to related and to approved network
associated companies (approved companies and from
network companies). qualifying activities
carried out on its own
The FTC may also carry out account.
specified qualifying activities on its
own account. With effect from 15 Tax exemption for
February 2007, FTCs may also dividend income
invest in unit trusts that engage received in Singapore
wholly in qualifying activities that from approved foreign
FTCs can carry out on their own investments.
account.

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.

• Insurance MAS Approved insurance companies 10% tax on: Indefinite.


which engage in the business of
insuring and reinsuring offshore a) income arising
risks. from the business
of insuring and
reinsuring offshore
risks;

b) dividends and
interest from
outside Singapore;

c) gains from the sale


of offshore
investments; and

d) interest from ACU


deposits.

Approved general insurer which Tax deduction on 10 years, with


employs at least 1 underwriter with special reserves set window
at least 3 years of relevant aside for specified approval period
experience and demonstrates offshore risks. from 2 July 2002
substantial commitment to to 1 July 2012.
business development in
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

ii) have marine hull and liability b) dividends and


premiums of at least $3 million interest from
in the preceding financial year; outside Singapore;
and
c) gains from the sale
iii) demonstrate the degree of of offshore
expertise and extent of investments; and
underwriting and
developmental capabilities in d) interest from ACU
marine hull and liability deposits.
insurance in Singapore.

− Offshore Approved captive insurance Tax exemption on: 10 years, with


Captive company. window
Insurance a) income from approval period
insuring and from 17
reinsuring relevant February 2006
offshore risks; to 16 February
2011.
b) dividends and
interest from
outside Singapore;

c) gains from the sale


of offshore
investments; and

d) interest from ACU


deposits.

− Offshore Insurers must: Tax exemption on: 5 years, with


Specialised window
Insurance i) underwrite at least 1 of the a) income from approval period
offshore qualifying specialised insuring and from 1
insurance risks (terrorism, reinsuring relevant September 2006
political, energy and aviation offshore risks; to 31 August
and aerospace risks); and 2011.
b) dividends and
ii) employ at least 2 additional interest from
insurance professionals, 1 of outside Singapore;
whom possesses at least 7
years of relevant experience. c) gains from the sale
of offshore
investments; and

d) interest from ACU


deposits.

− Offshore Qualifying insurers performing 5% tax on: 5 years, with


Islamic Shari’ah-compliant activities. window
Insurance a) income from approval period
(Takaful) and Criteria that will be taken into insuring and from 1 April
Reinsurance consideration include the reinsuring relevant 2008 to 31
(Retakaful) incremental number of experienced offshore risks; December 2013.

41
Tax Incentives – Finance (continued)
Type ++ Requirements Incentives Relief Period

professionals significantly involved b) dividends and


in the Shari’ah-compliant activities interest from
and the applicant’s business plan. outside Singapore;

c) gains from the sale


of offshore
investments; and

d) interest from ACU


deposits.

• 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.

ii) reinsurance brokers providing


either general or life
reinsurance broking business;
and

iii) registered under the Insurance


Act.

Other criteria that will be taken into


consideration include incremental
professional headcount and
business plan.

• Offshore # Companies which engage in 10% tax on qualifying Indefinite.


Leasing offshore leasing of machinery or leasing income.
plant.

• Aircraft EDB Registered business trust or 5% or 10% tax on 5 years with


Leasing approved aircraft leasing company income from: provision for
Scheme that is a bona fide player with extension, with
(ALS) regional or worldwide networks that i) income from window
uses Singapore as an operations leasing of aircraft approval period
base for leasing and lease and aircraft from 1 March
management activities. engines; and 2007 to 29
February 2012.
To qualify for the 10% tax rate, the ii) income from
company must: specified ancillary
activities.
i) incur at least $4 million and $10
million in annual business Tax exemption on
spending (up to 70% of which interest payment for
may be interest payments to foreign loans taken up
banks) in Singapore by the third during relief period.
and fifth years of operation
respectively; and

42
Tax Incentives – Finance (continued)
Type ++ Requirements Incentives Relief Period

ii) employ at least 3 additional Depreciation period of


professionals by the third year aircraft extended to 20
of operation. years during relief
period.
Companies that commit to incur
higher annual business spending in
Singapore and employ more
professionals may qualify for the
lower rate of 5%.

Approved fund manager or trustee 10% tax on income


manager. from managing or
providing prescribed
services to approved
aircraft leasing
company or trust.

• High MAS Financial institution, sub-unit within 5% tax on qualifying 5, 7 or 10 years


Value-Added a financial institution, or third party income. for companies
Processing service provider providing approved during
Services prescribed processing services to a the period
Supporting financial institution or qualifying between 27
Financial processing services company. February 2004
Activities and 26 February
To qualify for the 5-year award, the 2009.
company must:

i) employ and maintain at least 8


professionals, to undertake the
prescribed processing services,
for each category of financial
activities; and

ii) provide the prescribed


processing services to 2 or
more countries other than
Singapore.

Other qualitative factors will also be


considered.

• Bond Market MAS i) Primary dealers trading in Tax exemption on Up to 31


Incentives Singapore Government income from such December 2013.
securities. trades.

ii) Non-resident non-individuals. Withholding tax


exemption on
qualifying income from
qualifying debt
securities (QDS).

iii) Financial institutions, 10% tax on qualifying


corporations and bodies of income from QDS.
persons in Singapore.

43
Tax Incentives – Finance (continued)
Type ++ Requirements Incentives Relief Period

iv) All investors. Tax exemption for Applicable to


qualifying income from QDS issued
QDS that are: from 16
February 2008
i) Islamic debt to 31 December
securities; 2013.

ii) long-dated, with at


least 10 years
tenure.

QDS means: Qualifying income Applicable to


from QDS means: QDS issued on
i) Singapore Government or after:
securities issued during the
period from 28 February 1998 to i) Interest; i) 28 February
31 December 2013; 1998.

ii) debt securities substantially ii) Discounts; ii) 27 February


arranged by financial 2004 (QDS
with 1 year
institutions in Singapore issued
during the period from 28 tenure or
February 1998 to 31 December less) or 17
February
2013; and
2006 (QDS
iii) Islamic debt securities with 1 year
tenure or
endorsed by a Shari’ah council
that provide periodic payouts more).
backed by a regular stream of iii) Payouts from iii) 1 January
income from underlying assets. Islamic debt 2005.
The securities must be securities; and
substantially arranged in
Singapore and issued during iv) Redemption iv) 15 February
the period from 1 January 2005 premiums, 2007.
to 31 December 2013. prepayment fees
and break costs.
Note: Debt securities lead
managed by FSI-BM financial
institutions are treated as being
substantially arranged in
Singapore.

• Structured # Structured products offered by a Tax exemption on Contracts


Products financial institution in Singapore. income derived by entered into
non-resident during the
non-individuals. period from 1
January 2007 to
31 December
2011.

44
Tax Incentives – Finance (continued)
Type ++ Requirements Incentives Relief Period

• Infrastructure A qualifying infrastructure project is


Project one which invests in specified
Finance industry areas.

#/MAS i) Qualifying debt securities i) Tax exemption on Issued during


issued to finance a qualifying interest income on the period from 1
infrastructure project. qualifying project November 2006
Restrictions apply on the source debt securities. to 31 December
of funding for interest payments, 2011.
the use of the funds raised and
the minimum number of holders
of the securities.

ii) The issue must be lead ii) 5% tax on income


managed by a FSI-PF or derived by a
FSI-BM company, or FSI-Project
substantially arranged in Finance or FSI-BM
Singapore by a financial company from
institution in Singapore. services related to
the project. See
FSI scheme.

iii) Offshore interest income iii) Tax exemption on


received by a Singapore- interest income.
resident entity listed on the
Singapore Exchange or its
wholly-owned Singapore-
resident subsidiary.

iv) Transfer of qualifying iv) Remission of


infrastructure projects/assets to stamp duty
entities listed or to be listed on payable on the
the Singapore Exchange. instruments of
transfer.

v) Approved fund manager or v) 10% tax on income Up to 10 years,


trustee manager of from providing with window
Singapore-listed business management approval period
trusts and funds that own services in relation from 1 April
offshore infrastructure assets. to offshore 2008 to 31
infrastructure December 2011.
Further details to be released. assets.

++ Application is to be made to:

CPF - Central Provident Fund Board


EDB - Singapore Economic Development Board
IES - International Enterprise Singapore
MAS - Monetary Authority of Singapore
MOF - Ministry of Finance
MPA - Maritime and Port Authority of Singapore
SPRING - Standards, Productivity and Innovation Board
STB - Singapore Tourism Board

# No application required – incentive to be claimed upon submission of tax return to the IRAS.

45
Special Tax Deductions
Type ++ Requirements Benefit

• R&D # A company which incurs expenditure on R&D Deduction for R&D


Expenses projects outsourced to an overseas R&D expenses.
organisation, where the R&D is related to the
company’s trade or business, and ownership of the
intellectual property created accrues to the
company.

# A company which incurs expenditure on R&D Deduction for R&D


projects, where the R&D is conducted in expenses, with further
Singapore. Prior to YA 2009, the R&D must be deduction of 50% of R&D
related to the company’s trade or business. expenses incurred from
YA 2009 to YA 2013.
Further details to be released.

EDB A company or R&D organisation which incurs Further deduction for


expenditure on R&D projects, where the R&D is R&D expenses up to a
conducted in Singapore. Prior to YA 2009, the specified amount.
R&D must be related to the company’s trade or
business.

Further details to be released.

# A company with chargeable income for any year Tax deduction of up to


from YA 2009 to YA 2013 which incurs qualifying $150,000, claimable in
incremental expenditure on in-house R&D in subsequent years of
Singapore in the year of claim. assessment to the extent
of qualifying incremental
Further details to be released. R&D expenses incurred
during the basis period.

• 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.

• Export IES/ Resident companies or permanent establishments Double deduction for


Promotion STB carrying on business in Singapore which: export promotion and
and Market market development
Development i) participate in approved trade fairs, overseas expenses up to a
missions/market development activities; specified amount.

ii) set up approved overseas trade offices;

iii) hold the rights to master franchise or master


intellectual property licence;

iv) advertise in approved local trade publications;


or

v) carry out approved marketing projects.

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:

i) carry out investment feasibility or due diligence i) third party


studies or investment study missions or site consultancy fees and
visits. airfare and
allowances for
employees.

ii) operate and maintain overseas project ii) office facilities,


development offices for the purpose of remuneration,
identifying, initiating and developing investment accommodation,
opportunities in countries which are not allowances and
traditional investment locations that are already airfares for
familiar to Singapore investors. employees.

• 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.

Initially granted for 5


years with extension.

• 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.

iii) Display of privately-owned artworks in public. Double deduction for


initial installation cost of
artwork and
maintenance expenses
incurred.

• Donations # i) Cash donation to institutions of a public Double deduction for the


character (IPCs) and w.e.f. 1 January 2008, to amount donated.
approved grantmaking organisations.

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.

# iv) Gifts of buildings and land parcels. Double deduction for


appraised value.

• 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).

• Fixtures, # Expenditure on fixtures, fittings and installations Deductible over 3 years


Fittings and incurred from 16 February 2008 to 15 February on a straight-line basis.
Installations 2013, capped at $150,000 every 3 years.

Further details to be released.

* Application is to be made to:

EDB - Singapore Economic Development Board


IDA - Infocomm Development Authority of Singapore
IES - International Enterprise Singapore
MAS - Monetary Authority of Singapore
MOM - Ministry of Manpower
NHB - National Heritage Board
STB - Singapore Tourism Board

# 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.

Transfer Pricing Guidelines


The IRAS issued transfer pricing guidelines on 23 February 2006 to supplement the transfer pricing
provisions already existing in the Income Tax Act and the various Double Taxation Agreements signed by
Singapore. The guidelines cover the application of the arm' s length principle and documentation
requirements relating to all related party transactions, including local related party transactions.

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.

Country Air Transport Shipping Dividends (2a) Interest Royalties

Australia Exempt Exempt 15% 10% 10% (4a)

Austria Exempt Exempt 0% or 10% (2b) 5% (3b, d) 5%

Bahrain Exempt Exempt Exempt 5% (3b) 5%

Bangladesh Exempt 50% of normal 15% 10% 10% (4a)


rate

Belgium (1b) Exempt Exempt 15% 10% 5%

Brunei Exempt Exempt 10% 5% or 10% 10%


(3a, b)

Bulgaria Exempt Exempt 5% (2b) 5% (3b) 5%

Canada Exempt Exempt 15% 15% 15% (4g)

China Exempt Exempt 5% or 10% (2c) 7% or 10% 10%


(3a, b)

Cyprus Exempt Exempt Exempt 7% or 10% 10%


(3a, b)

Czech Republic Exempt 50% of normal 5% Exempt 10%


rate

Denmark Exempt Exempt 0%, 5% or 10% 10% (3b) 10%


(2b)

Egypt Exempt Exempt 15% 15% (3b) 15% (4g)

Estonia Exempt Exempt 5% or 10% 10% (3b) 7.5%


(2b, c)

Fiji Exempt Exempt 5% or 15% 10% (3b) 10%


(2b, c)

Finland Exempt Exempt 0%, 5% or 10% 5% (3b) 5%


(2b)

France Exempt Exempt 10% or 15% 10% (3b, c) Exempt (4a)


(2c)

Germany Exempt Exempt 5% or 15% (2c) 8% (3b) 8%

Hungary Exempt 50% of normal 5% or 10% (2b) 5% (3b, d) 5%


rate

India Exempt Exempt 10% or 15% 10% or 15% 10%


(2c) (3a)

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

Israel Exempt Exempt Exempt 7% (3b) 5%

Italy Exempt Exempt Exempt 12.5% (3b) 15% or 20%


(4g)

Japan Exempt Exempt 5% or 15% (2c) 10% (3b) 10%

Kazakhstan Exempt Exempt 5% or 10% 10% (3b) 10%


(2b, c)

Kuwait Exempt Exempt Exempt 7% (3b) 10%

Latvia Exempt Exempt 5% or 10% (2b) 10% (3b) 7.5%

Lithuania Exempt Exempt 5% or 10% (2b) 10% (3b) 7.5%

Luxembourg 50% of normal 50% of normal 5% or 10% (2b) 10% (3b) 10%
rate rate

Malaysia Exempt Exempt 5% or 10% 10% (3b, f) 8%


(2c)

Malta (1c) Exempt Exempt At domestic 7% or 10% 10%


rates (2b) (3a, b)

Mauritius Exempt 50% of normal Exempt Exempt Exempt


rate

Mexico Exempt 50% of normal Exempt 5% or 15% 10%


rate (3a, b)

Mongolia Exempt Exempt 5% or 10% (2b) 5% or 10% 5%


(3a, b)

Morocco (1a) (1a) (1a) (1a) (1a)

Myanmar Exempt 50% of normal Exempt 8% or 10% 10% or 15%


rate (3a, b) (4c, g)

Netherlands Exempt Exempt Exempt or 15% 10% (3b) Exempt (4a)

New Zealand Exempt Exempt 15% 15% 15% (4a, g)

Norway Exempt Exempt 5% or 15% (2b) 7% (3b) 7%

Oman Exempt Exempt 5% (2b) 7% (3b) 8%

Pakistan Exempt 50% of normal 10% 12.5% (3b) 10% (4a)


rate

Papua New Exempt Exempt 15% 10% 10%


Guinea

Philippines Up to 1.5% of Up to 1.5% of 15% or 25% 15% (3e) 15% or 25%


gross revenue gross revenue (2c) (4e, g)
generally generally

50
Double Taxation Agreements (continued)
Country Air Transport Shipping Dividends (2a) Interest Royalties

Poland Exempt 50% of normal 10% (2b) 10% (3b) 10%


rate

Portugal Exempt Exempt 10% (2b) 10% (3b, e) 10%

Qatar Exempt Exempt Exempt 5% (3b) 10%

Romania Exempt Exempt 5% (2b) 5% (3b) 5%

Russian (1a) (1a) (1a) (1a) (1a)


Federation

Slovak Exempt Exempt 5% or 10% Exempt 10%


Republic (2b, c)

South Africa Exempt Exempt 5% or 15% (2b) Exempt 5%

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)

Switzerland Exempt 50% of normal 10% or 15% 10% (3f) 5% (4a, e)


rate

Taiwan Exempt Up to 2% of 40% (including At domestic 15% (4a, g)


gross revenue corporate tax) rates

Thailand Exempt 50% of normal 20% generally 10% or 25% 15% (4g)
rate (3a, b)

Turkey Exempt 50% of normal 10% or 15% 7.5% or 10% 10%


rate (2b) (3a, b)

Ukraine (1a) (1a) (1a) (1a) (1a)

United Arab - Exempt 5% 7% (3b) 5% (4f)


Emirates

United Exempt Exempt 5% or 15% (2c) 10% (3b) 10%


Kingdom

Vietnam Exempt Exempt 5%, 7% or 10% (3b) 5% or 15%


12.5% (2b) (4c, g)

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%.

Air Transport/Shipping Agreements


Country I Region Air Transport Shipping

Bahrain (note 1) Exempt -

Chile - Exempt

Hong Kong SAR Exempt Exempt

Oman (note 2) Exempt -

Saudi Arabia Exempt -

United Arab Emirates Exempt -

United States of America Exempt 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

Returns Relating to Taxpayer's


Income

• Resident individual income tax Form B/B1 or


return e-file

• Non-resident individual income tax Form M


return Within 1 month of
By 15 April or by issue date of
• Partnership income tax return Form P extension date. notice of
assessment (see
• Associations, clubs and other Form P1 page 55) or as per
societies income tax return pre-arranged
instalment
• Trust and estate income tax return Form T
payment plan.
• Company income tax return Form C For YAs 2008 and
2009, by 30
November and 31
October respectively.

• 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

Employer's Returns Relating to


Employee's Income

• 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

Returns Relating to Withholding


Tax on Certain Payments to
Non-Residents

• Interest, royalty, technical fee,


management fee

• Directors'remuneration
Form IR37
• Certain distribution by approved
unit trusts

• Rent on movable properties By the 15th of the


month following the
• Sale of real properties Form IR37A date of payment or Due date for filing.
deemed payment to
• Supplementary Retirement Form IR37B non-resident.
Scheme (SRS) withdrawals

• Non-resident professional fees Form IR37C/


Form IR586 (if
treaty exemption
is applicable)

• Non-resident public entertainer Form IR37D


fees (w.e.f. 1 January 2008)

Where reduced withholding rate is Certificate of By 31 March of Not applicable.


applicable under a double taxation Residence from following year or by
agreement Non-resident extension date.

GST Returns for Registered


Taxable Persons

• 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

Other Tax Notifications

• Notification of chargeability of tax Registration Form By 14 April if no tax Not applicable.


by new taxpayers for New Taxpayer return has been
issued to that person.
In the case of an
individual who arrives
in Singapore during
the year, within 1
month of the date of
arrival.

• Notification of estimate of IRIN 320/322 or Within 3 months after Where maximum


chargeable income from a trade or e-file financial year end. instalments are
business required, first
instalment of tax
must be paid 1 month
immediately
following the financial
year end.

Notification of Tax Charged or


Computed By Tax Comptroller

• Notice of assessment to income Within 30 days of Within 1 month of


tax issue of the notice of issue date of notice
assessment: of assessment or as
per pre-arranged
N/A • To lodge objection instalment payment
if assessment is plan.
disputed.

Form GR-A/GR-B • To submit group


relief application if
company can
qualify
consequent to the
assessment.

Election Form for • To submit election


Individuals for form if individual
Carry-Back of can qualify
Capital consequent to the
Allowances and assessment.
Trade Losses

• Computation of partners'share of N/A If disputed, objection Not applicable.


profits to be filed within 30
days of issue date of
computation.

55
Your PricewaterhouseCoopers Contacts
Tax Partners
Corporate Tax
Paula Eastwood [email protected] 65 6236 3648

Chan-Cheng Wei [email protected] 65 6236 3808


Paul Cornelius [email protected] 65 6236 3718
Nicole Fung [email protected] 65 6236 3618
Abhijit Ghosh [email protected] 65 6236 3888
Jenny Goh [email protected] 65 6236 3638
Ho Mui Peng [email protected] 65 6236 3838
Anuj Kagalwala [email protected] 65 6236 3822
Paul Lau [email protected] 65 6236 3733
Elaine Ng [email protected] 65 6236 3627
David Sandison [email protected] 65 6236 3675
Peter Tan [email protected] 65 6236 3668
Chris Woo [email protected] 65 6236 3688
Yip Yoke Har [email protected] 65 6236 3938
Rex Young [email protected] 65 6236 3608

Personal Tax
James Clemence [email protected] 65 6236 3948

Goods & Services Tax


Koh Soo How [email protected] 65 6236 3600

Visit our Singapore tax website at www.pwc.com/sg/tax


Copyright@2008 PricewaterhouseCoopers Singapore. All rights reserved.

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

56
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Notes:

58
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