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Principal Tax Contact
Soh Pui Ming +65 6309-8215
Email: pui.ming.soh@sg.ey.com
International Tax and Transaction Services – International Corporate Tax Advisory
Soh Pui Ming +65 6309-8215
Email: pui.ming.soh@sg.ey.com
Chester Wee, Asean International +65 6309-8230
Corporate Tax Advisory Leader
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Lim Gek Khim +65 6309-8452
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Russell Aubrey +65 6309-8690
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Tan Chee Wei +65 6540-7168
Email: chee.wei.tan@sg.ey.com
Tan Bin Eng, +65 6309-8738
Business Incentives Advisory
Email: bin-eng.tan@sg.ey.com
Johanes Candra, +65 6309-8158
Business Incentives Advisory Email: johanes.candra@sg.ey.com
International Tax and Transaction Services – Global Tax Desk Network
Koji Hisada, Japan
+65 6309-6295
Email: koji-k.hisada@sg.ey.com
Cap Perry, United States +65 6718-1066
Email: cap.perry1@sg.ey.com
Gaurav Suresh Ashar, India +65 6340-2150
Email: gaurav.s.ashar@sg.ey.com
Changwon Lee, Korea (South) +65 6718-1055
Email: changwon.lee1@sg.ey.com
International Tax and Transaction Services – Operating Model Effectiveness
Paul Griffiths
+65 6309-8068
Email: paul.griffiths@sg.ey.com
Nick Muhlemann +65 6309-6709
Email: nick.muhlemann@sg.ey.com
Tax Technology and Transformation
Ong See Yew
Tax and Finance Operate
+65 6309-8106
Email: see.yew.ong@sg.ey.com
Elaine Yeo +65 6309-8810
Email: elaine.yeo@sg.ey.com
International Tax and Transaction Services – Transfer Pricing
Luis Coronado, +65 6309-8826
EY Global Transfer Pricing Leader Email: luis.coronado@sg.ey.com and Tax Controversy Leader
Stephen Lam +65 6309-8305
Email: stephen.lam@sg.ey.com
Jonathan Belec +65 6309-6175
Email: jonathan.belec@sg.ey.com
Chai Sui Fun +65 6718-1128
Email: sui.fun.chai@sg.ey.com
Sharon Tan +65 6309-6375
Email: sharon.tan@sg.ey.com
Rachel Kok +65 6718-1388
Email: rachel.kok@sg.ey.com
International Tax and Transaction Services – Transaction Tax Advisory
Darryl Kinneally +65 6309-6800
Email: darryl.kinneally@sg.ey.com
Sandie Wun +65 6309-8081
Email: sandie.wun@sg.ey.com
Business Tax Services
Choo Eng Chuan, +65 6309-8212
Private Client Services Email: eng.chuan.choo@sg.ey.com
Desmond Teo, +65 6309-6111
Private Client Services Email: desmond.teo@sg.ey.com Angela Tan, +65 6309-8804 Tax Policy and Controversy Email: angela.tan@sg.ey.com
Financial Services
Amy Ang, Asia-Pacific +65 6309-8347
Financial Services Tax Leader Email: amy.ang@sg.ey.com Stephen Bruce +65 6309-8898
Email: stephen.bruce@sg.ey.com
Mriganko Mukherjee +65 6309-8013
Email: mriganko.mukherjee@sg.ey.com
Louisa Yeo +65 6309-6479 Email: louisa.yeo@sg.ey.com
Rajesh Bheemanee +65 6309-8274
Email: rajesh.bheemanee@sg.ey.com
Adrian Halter +65 6309-8778
Email: adrian.halter@sg.ey.com
Moong Jee See +65 6718-1033
Email: jee.see.moong@sg.ey.com
May Tay +65 6505-2410
Email: may.tay@sg.ey.com
Louisa Yeo +65 6309-6479
Email: louisa.yeo@sg.ey.com
Tom Toryanik +65 6540-7268
Email: tom.toryanik@sg.ey.com
Global Compliance and Reporting
Chai Wai Fook +65 6309-8775
Email: wai-fook.chai@sg.ey.com
Chia Seng Chye +65 6309-8359
Email: seng.chye.chia@sg.ey.com
Goh Siow Hui
+65 6309-8333
Email: siow.hui.goh@sg.ey.com
Ivy Ng +65 6309-8650
Email: ivy.ng@sg.ey.com
Helen Bok +65 6309-8943
Email: helen.bok@sg.ey.com
Teh Swee Thiam +65 6309-8770
Email: swee-thiam.teh@sg.ey.com
Toh Ai Tee +65 6309-8486
Email: ai-tee.toh@sg.ey.com
Toh Shu Hui +65 6309-8375
Email: shu-hui.toh@sg.ey.com
Olivia Yeoh, +65 6340-2128
Corporate Services
People Advisory Services
Email: olivia.yeoh@sg.ey.com
Panneer Selvam +65 6309-8483
Email: panneer.selvam@sg.ey.com
Kerrie Chang +65 6309-8341
Email: kerrie.chang@sg.ey.com
Sarah Lane +65 6309-8041
Email: sarah.lane@sg.ey.com
Indirect Tax
Yeo Kai Eng +65 6309-8208
Email: kai.eng.yeo@sg.ey.com
Chew Boon Choo +65 6309-8764
Email: boon-choo.chew@sg.ey.com
Liza Drew +65 6340-2788
Email: liza.drew@sg.ey.com
Danny Koh +65 6309-6101
Email: danny.koh@sg.ey.com
A. At a glance
Corporate Income Tax Rate (%) 17 (a) Capital Gains Tax Rate (%) Not applicable Branch Tax Rate (%) 17 (a) Withholding Tax (%) (b)
Dividends 0 (b)(c)
Interest 15 (b)
Royalties from Patents, Know-how, etc. 10 (b) Branch Remittance Tax Not applicable Net Operating Losses (Years)
Carryback 1 (d) Carryforward Unlimited (d)
(a) Various tax exemptions and reductions are available (see Section B). (b) See Section F. (c) See Section B. (d) See Section C.
B. Taxes on corporate income and gains
Corporate income tax. Income tax is imposed on all income derived from sources in Singapore, and on income from sources outside Singapore if received in Singapore. However, a nonresi dent company that is not operating in or from Singapore is gener ally not taxed on foreign-source income received in Singapore. A company is resident in Singapore if the control and management of its business is exercised in Singapore; the place of incorporation is not relevant.
Remittances of foreign income in the form of dividends, branch profits and services income (specified foreign income) into Singapore by companies resident in Singapore are exempt from tax if prescribed conditions are met. For remittances of specified foreign income that does not meet the prescribed conditions, companies may be granted tax exemption under specific scenar ios or circumstances on an approval basis.
Rates of corporate income tax. The standard corporate income tax rate is 17%. Seventy-five percent of the first SGD10,000 of nor mal chargeable income is exempt from tax, and 50% of the next SGD190,000 is exempt from tax. The balance of chargeable in come is fully taxable at the standard rate of 17%.
Tax incentives, exemptions and reductions. Singapore offers a wide range of tax incentives that are generally granted on an approval basis to promote investments in selected industry sec tors, including the following:
• Pioneer companies and pioneer service companies. A pioneer enterprise is exempt from income tax on its qualifying profits for up to 15 years.
• Development and Expansion Incentive (DEI). DEI companies enjoy a concessionary tax rate of 5% or 10% on their incremen tal income derived from the performance of qualifying activi ties.
• Approved royalties, technical assistance fees and contributions to research and development (R&D) costs.
• Investment allowances.
• R&D incentives. An additional 150% tax deduction (effective from the 2019 year of assessment (YA) to the 2025 YA) is allowed for certain qualifying R&D expenditure.
• Intellectual Property (IP) Development Incentive. The IP Development Incentive is effective from 1 July 2018 to 31 December 2023. This incentive incorporates the Base Erosion and Profit Shifting (BEPS)-compliant modified nexus approach.
• Finance and treasury center incentive. Income derived from the provision of qualifying services to approved network compa nies and from the carrying on of qualifying activities on own account is subject to tax at a rate of 8%.
• Financial sector incentive (FSI). The FSI is designed to encour age the development of high-growth and high value-added financial activities in Singapore. A 5%, 10%, 12% or 13.5% concessionary tax rate applies to income derived from carrying on qualifying activities by approved FSI companies in Singapore.
• Maritime sector incentives. Ship operators, maritime lessors and providers of certain supporting shipping services may enjoy tax incentives under the Maritime Sector Incentive, which consists of the following three broad categories:
International shipping enterprise
Maritime (ship or container) leasing
Supporting shipping services
• Global Trader Programme (GTP). Under the GTP, approved companies enjoy a concessionary tax rate of 5% or 10% on qualifying transactions conducted in prescribed commodities and products.
Capital gains. Capital gains are not taxed in Singapore. However, in certain circumstances, the Singapore Revenue considers trans actions involving the acquisition and disposal of assets, such as real estate, stocks or shares to be the carrying on of a trade, and, as a result, gains arising from such transactions are taxable. The determination of whether such gains are taxable is based on a consideration of the facts and circumstances of each case.
Administration. The tax year, known as (YA), runs from 1 January to 31 December. The period for which profits are identified for assessment is called the basis year. Therefore, income earned during the 2020 basis year is assessed to tax in the 2021 YA. For companies engaged in business in Singapore that adopt an accounting period other than the calendar year, the assessable profits are those for the 12-month accounting period ending in the year preceding the YA.
An estimate of the chargeable income (ECI) of a company must be filed within three months after the end of its accounting year. However, companies are not required to file an ECI if their annual revenue is not more than SGD5 million for the financial year and if their ECI is nil.
The statutory deadline for filing the income tax return is 30 November. No extension of time to file the return is allowed and e-filing is mandatory for all companies.
Income tax is due within one month after the date of issuance of the notice of assessment. In certain circumstances, companies may pay tax in monthly installments on the ECI, up to a maximum of 10, with the first installment payable one month after the end of the accounting period. No installments are allowed if the ECI is submitted more than three months after the end of the relevant accounting period.
A late payment penalty of 5% of the tax due is imposed if the tax is not paid by the due date. If the tax is not paid within 60 days of the imposition of the 5% penalty, an additional penalty of 1% of the tax is levied for each complete month that the tax remains outstanding, up to a maximum of 12%.
Dividends. Dividends paid by a Singapore tax-resident company are exempt from income tax in the hands of shareholders, regard less of whether the dividends are paid out of taxed income or taxfree gains. No withholding tax is imposed on dividends.
Foreign tax relief. Singapore has entered into double tax agree ments with more than 90 countries, but notably not with the United States. Under Singapore rules, a foreign tax credit is limited to the lower of the foreign tax paid and the Singapore tax payable on that income. The foreign tax credit (FTC) is granted on a countryby-country, source-by-source basis unless the resident taxpayer elects to claim FTC under the pooling method, subject to meeting certain conditions.
A unilateral tax credit system, similar to FTC relief, is also avail able for income derived from countries that have not entered into double tax agreements with Singapore.
C. Determination of taxable income
General. In general, book profits reported in the financial statements prepared under the financial reporting standards in Singapore are adjusted in accordance with the Singapore tax rules to arrive at taxable income.
If a company maintains its financial accounts in a functional currency other than Singapore dollars, as required under the financial reporting standards in Singapore, it must furnish tax computations to the Singapore Revenue denominated in that functional currency in a manner as prescribed by the law.
For expenses to be deductible, they must meet all of the following conditions:
• They must be incurred wholly and exclusively in the production of income.
• They must be revenue in nature.
• They must not be specifically prohibited under the Singapore tax law.
To facilitate business start-ups, it is specifically provided that a person is treated as having commenced business on the first day of the accounting year in which the business earns its first dollar of business receipt. This is known as the deemed date of commencement, and businesses may deduct revenue expenses incurred in the accounting year (not exceeding a 12-month peri od) immediately preceding the deemed date of commencement. Special rules govern the deductibility of expenses for investment holding companies.
Expenses attributable to foreign-source income are not deductible unless the foreign-source income is received in Singapore and subject to tax in Singapore. In general, offshore losses may not be offset against Singapore-source income.
No deduction is allowed for the book depreciation of fixed assets, but tax depreciation (capital allowances) is granted according to statutory rates (see Capital allowances [tax depreciation]).
Double deductions. Double deductions are available for certain expenses relating to approved trade fairs, exhibitions or trade missions, maintenance of overseas trade offices, overseas investment development and approved salary expenditure for employees posted overseas. A sunset clause of 31 December 2025 applies to the double deduction schemes for these expenses.
Renovation or refurbishment deduction. A tax deduction is allow able on due claim, for qualifying renovation or refurbishment (R&R) expenditure incurred for the purposes of a trade, profession or business. The allowable R&R costs are capped at SGD300,000 for every three-year period, beginning with the basis period in which the deduction is first allowed. An option is available to accelerate the deduction of qualifying expenditure incurred on renovation or refurbishment for the 2021and 2022 YAs in one YA instead of over three consecutive YAs, subject to an expenditure cap of SGD300,000. Any unused R&R deduction is allowed as a loss carryback or loss carryforward (see Relief for trading losses) or for group relief (see Groups of companies).
Inventories. Trading inventory is normally valued at the lower of cost or net realizable value. Cost must be determined on a firstin, first-out (FIFO) basis; the last-in, first-out (LIFO) basis is not accepted.
Provisions. Under FRS 109 Financial Instruments, impairment losses that represent 12-month expected credit loss (ECL) or lifetime ECL are recognized if some risk of default exists or even in the absence of loss events. Only impairment losses recognized in the profit and loss statement with respect to the creditimpaired financial instruments on revenue account are allowed for tax deduction, and any reversal amount subsequently recog nized in the profit and loss statement will be taxable.
Capital allowances (tax depreciation)
Plant and machinery. Tax depreciation or capital allowances are given for capital expenditures incurred on the acquisition of plant and machinery used for the purposes of a trade or business. Qualifying plant and machinery are normally written off in equal amounts over three years when claimed. An option is available to accelerate the capital allowances claim for plant and machinery acquired for the 2021 and 2022 YAs over two years (that is, 75% of the cost in the first YA and the remaining 25% in the second YA). Alternatively, expenditures on such assets may be claimed in one year if each item costs no more than SGD5,000. However, the total claim for all such assets may not exceed SGD30,000 for a YA.
The cost of the following may be written off in one year:
• Computers or other prescribed automation equipment
• Websites
• Generators
• Robots
• Certain industrial noise- and chemical hazards-control equip ment
Only expenditure on certain automobiles, such as commercial vehicles and cars registered outside Singapore and used exclu sively outside Singapore, qualify for capital allowances.
Land intensification allowance incentive. The land intensifica tion allowance (LIA) incentive grants an initial allowance of 25% and an annual allowance of 5% on qualifying capital expenditure incurred on or after 23 February 2010 by businesses on the con struction or renovation of qualifying buildings or structures if certain conditions are met. The application window period for the LIA incentive is from 1 July 2010 through 31 December 2025.
Intellectual properties. Writing-down allowances (WDAs) are granted for capital expenditure incurred on the acquisition of specified categories of intellectual property (IP) on or before the last day of the basis period for the 2025 YA if the legal and eco nomic ownership of the IP lies with Singapore companies. Companies may elect a 5-, 10- or 15-year amortization period. This election is irrevocable.
On application, the legal ownership requirement may be waived for IP rights acquired on or after 17 February 2006 if the Singapore company has substantial economic rights over the IP, while the foreign parent holds the legal title.
Disposal of plant and equipment. Allowances are generally sub ject to recapture on the sale of qualifying plant and equipment if the sales proceeds exceed the tax-depreciated value (to the extent of the excess but not more than the allowances claimed). If sales proceeds are less than the tax-depreciated value, an additional allowance may be given.
Relief for trading losses. Trading losses may be offset against all other chargeable income of the same year. Unused losses may be carried forward indefinitely, subject to the shareholding test (see below). Excess capital allowances can also be offset against other chargeable income of the same year and carried forward indefi nitely subject to the shareholding test and to the requirement that the trade giving rise to the capital allowances continues to be carried on (same trade test).
A one-year carryback of up to an aggregate amount of SGD100,000 of current-year unused capital allowances and trade losses (col lectively referred to as “qualifying deductions”) may be allowed, subject to meeting certain conditions and compliance with speci fied administrative procedures.
The carryforward and carryback of losses and capital allowances are subject to the shareholders remaining substantially (50% or more) the same at the relevant comparison dates (shareholding test). If the shareholder of the loss company is itself another com pany, look-through provisions apply through the corporate chain to the final beneficial shareholder.
The carryback of capital allowances is subject to the same trade test that is applicable to the carryforward of unused capital allow ances.
The Singapore Revenue has the authority to allow companies to deduct their unused tax losses and capital allowances, notwith standing a substantial change in ownership at the relevant dates, if the change is not motivated by tax considerations. If allowed, these losses and capital allowances may be offset only against profits from the same business.
Groups of companies. Under group relief measures, current-year unused losses, capital allowances and donations may be trans ferred by one company to another within a group, subject to meet ing certain qualifying conditions. A group generally consists of a Singapore-incorporated parent company and all of its Singaporeincorporated subsidiaries. Two Singapore-incorporated compa nies are members of the same group if one is 75% owned by the other, or both are 75% owned by a third Singapore-incorporated company.
D. Other significant taxes
The following table summarizes other significant taxes.
Nature of tax Rate (%)
Goods and Services Tax (GST) on any supply of goods and services, except an exempt supply, made in Singapore by a taxable person (a person whose annual taxable supplies exceed or are expected to exceed SGD1 million) in the course
Nature of tax Rate (%)
of or furtherance of business and on imports of goods into Singapore unless the imports qualify for import reliefs; effective from 1 January 2020, GST is also imposed on business-to-business supplies of imported services by way of reverse charge and business-to-consumer (B2C) supplies of imported digital services via the Overseas Vendor Registration (OVR) regime; effective from 1 January 2023, GST will also be imposed on B2C supplies of imported non-digital services through the OVR regime; the GST rate will be increased from the current 7% to 8% on 1 January 2023, and from 8% to 9% on 1 January 2024 0/7
Social security contributions (Central Provident Fund [CPF]); foreigners holding work passes are exempt
For employees up to age 55, on monthly ordinary wages (lower rates apply if employee is older than age 55); the monthly salary ceiling for contributions is SGD6,000 for ordinary wages; contributions paid by Employer (limited to SGD1,020 a month) 17 Employee (limited to SGD1,200 a month) 20 Contributions on additional wages, such as bonuses and non-regular payments (limited to SGD102,000 less the total ordinary wages subject to CPF contributions in the year); paid by Employer 17 Employee 20 (The employer’s and employee’s contribution rate for workers aged from above 55 to 60 is 14%; lower contribution rates apply to individuals older than age 60. The government has announced that the CPF contribution rates for workers aged 55 to 70 will be gradually raised until 2030. For employees who earn total wages of less than SGD750 per month, different rates apply.) Skills development levy; payable by employer for all employees; based on the first SGD4,500 of monthly gross remuneration; subject to a minimum of SGD2 0.25
E. Miscellaneous matters
Foreign-exchange controls. Singapore does not impose any restrictions on the remittance or repatriation of funds in or out of Singapore.
Debt-to-equity ratios. In general, Singapore does not impose any specific debt-to-equity restrictions.
Anti-avoidance legislation. The domestic tax legislation allows the Singapore Revenue to disregard or vary any arrangement that has the purpose or effect of altering the incidence of taxation or reducing or avoiding Singapore tax liability. The Singapore
Revenue may also tax profits of a nonresident in the name of a resident as if the latter is an agent of the nonresident, if the profits of the resident from business dealings with the nonresident are viewed as lower than expected as a result of the close connection between the two parties.
The Singapore Revenue has introduced a 50% surcharge to be imposed on a taxpayer of the tax assessed on any adjustments that the Singapore Revenue has made pursuant to the anti-tax avoid ance legislation. This surcharge will apply with effect from the 2023 YA. The Multilateral Convention to Implement Tax Treaty Related Measures to Prevent Base Erosion and Profit Shifting (MLI) entered into force on 1 April 2019. As of 1 January 2022, Singapore’s tax treaties with more than 40 jurisdictions have been amended by the MLI.
Transfer pricing. Specific legislation governs the arm’s-length principle to be applied to related-party transactions. The Singapore Revenue may make adjustments to the amount of income, deduction or loss of a taxpayer in cases in which the terms of commercial relations or financial relations between two related parties are not at arm’s length. A 5% surcharge is imposed on transfer-pricing (TP) adjustments made for noncompliance with the arm’s-length principle. A remission on the 5% surcharge may be granted under certain circumstances and subject to conditions.
The Singapore Transfer Pricing Guidelines provide guidance on the arm’s-length principle and TP documentation requirements in Singapore. The guidelines on the application of the arm’s-length principle are broadly consistent with the Organisation for Economic Co-operation and Development (OECD) Transfer Pricing Guidelines for Multinational Enterprises and Tax Administrations, which endorse the arm’s-length principle. Specific guidance, including a recommendation to adopt a threestep approach (conduct a comparability analysis, identify the most appropriate TP method and tested party, and determine the arm’s-length results) to apply the arm’s-length principle, is provided together with specific requirements relating to external benchmarking searches and the application of results.
The Singapore Revenue expects companies to maintain contem poraneous TP documentation. Effective from the 2019 YA, Singapore taxpayers are required to prepare contemporaneous TP documentation, if certain conditions are satisfied, to support their transactions with related parties, unless specifically exempted. The Singapore Revenue does not require TP documentation to be submitted together with the tax returns but taxpayers have 30 days to submit the documents on the Singapore Revenue’s re quest. Failure to prepare contemporaneous documentation or the inability of taxpayers to substantiate transfer prices may result in the imposition of penalties for noncompliance, upward adjust ment, ineligibility to invoke competent authority assistance, re jection of an Advance Pricing Arrangement (APA) application and disallowance of self-initiated adjustments. The TP documen tation must be organized at the group level and entity level.
TP administration provides information and guidance on the TP audit process and the avoidance and resolution of TP disputes. The TP audit process involves the Singapore Revenue selecting taxpayers based on various risk indicators and reviewing and auditing their TP methods and documentation. The guidelines also provide details on the step-by-step processes for the Mutual Agreement Procedure (MAP) and APAs, including sample docu ments for the MAP and APAs. Double tax agreements provide for the MAP to resolve instances of double taxation. MAP is a dispute-resolution process used by the competent tax authorities to resolve disputes arising under the application of double tax agreements.
Discussion and guidance are also provided with respect to TP adjustments, related-party loans, services and attribution of prof its to permanent establishments (PEs).
Country-by-Country Reporting. On 21 June 2017, Singapore signed the Multilateral Competent Authority Agreement on exchange of Country-by-Country (CbC) Reports (CbCR MCAA), which enables Singapore to efficiently establish a wide network of exchange relationships for the automatic exchange of CbC Reports. As of 29 April 2021, the Singapore Revenue has acti vated bilateral Automatic Exchange of Information relationships for the exchange of CbC Reports with 80 jurisdictions; these fa cilitate the automatic exchange of CbC Reports for the Ultimate Parent Entity of Singapore multinational enterprise (MNE) groups.
Common Reporting Standard. Singapore has implemented the Common Reporting Standard (CRS), an internationally agreed standard for the automatic exchange of financial account information in tax matters. On 21 June 2017, Singapore signed the CRS Multilateral Competent Authority Agreement (CRS MCAA), which enables Singapore to efficiently establish a wide network of exchange relationships for the automatic exchange of information based on CRS. As of March 2022, there have been more than 90 signatories to the CRS MCAA, and the Singapore Revenue has also concluded more than 10 bilateral Competent Authority Agreements. The first exchange took place in September 2018.
Carbon tax. The Singapore government has implemented a carbon tax on the emission of greenhouse gases from 2019. The carbon tax rate is SGD5 per ton of carbon dioxide-equivalent (tCO2e) of emissions. The carbon tax rate will be increased to SGD25 per tCO2e in 2024 and 2025, SGD45 per tCO2e in 2026 and 2027, with a view to reach SGD50 to SGD80 per tCO2e by 2030.
International Compliance Assurance Programme. The International Compliance Assurance Programme (ICAP) is an OECD initiative and is a voluntary risk assessment and assurance program to fa cilitate cooperative multilateral engagements between MNEs and tax administrations, which will provide MNEs with increased tax certainty on certain of their activities and transactions. The Singapore Revenue has announced it is participating in the ICAP from 2021.
F. Domestic and treaty withholding tax rates
A 15% withholding tax, with certain exceptions, is imposed on interest and other payments with respect to loans or indebtedness paid to nonresidents.
A 10% withholding tax, with certain exceptions, is imposed on the following types of payments to nonresidents:
• Royalties for the use of, or the right to use, movable property
• Payments for the use of, or the right to use, scientific, technical, industrial or commercial knowledge or information
A 17% withholding tax is imposed on payments to nonresident companies for assistance or services rendered in connection with the application or use of scientific, technical, industrial or com mercial knowledge or information, and for management or assis tance in the management of any trade, business or profession. If services are performed outside Singapore, payments for such services are not subject to withholding tax.
The rates of withholding tax on interest and royalties may be re duced under the terms of a double tax agreement, and details of the rates applicable to treaty jurisdictions are set out below.
Interest Royalties (i) % %
Albania 5 (a) 5 (cc)
Armenia (z) 5 (a) 5 (cc)
Australia 10 10 (gg)
Austria 5 (a) 5 Bahrain 5 (a) 5
Bangladesh 10 10
Barbados 12 (a) 8 (cc) Belarus 5 (a) 5 (w)
Belgium 5 (a) 3/5 (p)
Brazil (ff) 10/15 (a)(ii) 10/15 (jj)
Brunei Darussalam 5/10 (a)(m) 10 Bulgaria 5 (a) 5 Cambodia 10 (a) 10
Canada 15 (a) 15
China Mainland 7/10 (a)(b) 6/10 (p) Cyprus 7/10 (a)(b) 10 (cc)
Czech Republic 0 0/5/10 (x)
Denmark 10 (a) 10
Ecuador 10 (a) 10
Egypt 15 (a) 15
Estonia 10 (a) 7.5
Ethiopia 5 5 (bb)(cc)
Fiji 10 (a) 10
Finland 5 (a) 5
France 10 (a) 0 (kk)
Georgia 0 0 (cc)
Germany 0 5 (cc)
Ghana 7 (a) 7 (cc)
Guernsey 12 (a) 8 (cc)
Hungary 5 (a) 5
India 10/15 (a)(c) 10 Indonesia 10 (a) 8/10 (ll)
Ireland 5 (a) 5 (cc)
Interest Royalties (i) % %
Isle of Man 12 (a) 8 (cc)
Israel 7 (a) 5 (q)
Italy 12.5 (a) 15/20 (t)
Japan 10 (a) 10
Jersey 12 (a) 8 (cc)
Jordan (mm) 5 (a) 5
Kazakhstan (hh) 10 (a) 10
Korea (South) 10 (a) 5 (cc)
Kuwait 7 (a) 10
Laos 5 (a) 5 (cc)
Latvia 0/10 (aa) 5 (cc)
Libya 5 (a) 5 (cc)
Liechtenstein 12 (a) 8 (cc)
Lithuania 10 (a) 7.5
Luxembourg 0 7 (cc)
Malaysia 10 (a) 8
Malta 7/10 (a)(b) 10
Mauritius 0 (u) 0 (u)
Mexico 5/15 (a)(d) 10 Mongolia 5/10 (a)(m) 5 Morocco 10 (a) 10 Myanmar 8/10 (a)(e) 10/15 (j)
Netherlands 10 (a) 0
New Zealand 10 (a) 5
Nigeria (nn) 7.5 (a) 7.5 (cc)
Norway 7 (a) 7 Oman 7 (a) 8
Pakistan 12.5 (a) 10 Panama 5 (a) 5
Papua New Guinea 10 (a) 10 (a)
Philippines 10/15 (a)(r) 15/25 (k)(s)
Poland 5 (a) 2/5 (p)
Portugal 10 (a) 10 Qatar 5 (a) 10 Romania 5 (a) 5 Russian Federation 0 5 (cc)
Rwanda 10 (a) 10 (cc)
San Marino 12 (a) 8 (cc)
Saudi Arabia 5 (a) 8
Serbia (oo) 10 (a) 5/10 (pp)
Seychelles 12 (a) 8 (cc)
Slovak Republic 0 10
Slovenia 5 (a) 5 (cc)
South Africa 7.5 (a) 5 (cc)
Spain 5 (a) 5 (cc)
Sri Lanka 10 (a) 10 (dd)
Sweden 10/15 (a)(f) 0 (qq) Switzerland 5 (a) 5 (g)
Taiwan (n) 15
Thailand 10 (a)(v) 5/8/10 (y)
Tunisia 5/10 (a)(d) 5/10 (rr)
Turkey 7.5/10 (a)(h) 10
Turkmenistan 10 (a) 10 (cc)
Ukraine 10 (a) 7.5
Interest Royalties (i)
%
United Arab Emirates 0 5 (l)(cc)
United Kingdom 5 (a) 8 (cc)
Uruguay 10 (a)(ss) 5/10 (cc)(ee)
Uzbekistan 5 8 (cc)
Vietnam 10 (a)(tt) 5/10 (o)
Non-treaty jurisdictions 15 10
(a) Exempt under certain specified circumstances.
(b) The rate is 7% for interest paid to banks or financial institutions.
(c) The 10% rate applies to interest paid to financial institutions. The 15% rate applies to other interest.
(d) The rate is 5% for interest paid to banks or similar financial institutions..
(e) The rate is 8% for interest paid to banks or financial institutions.
(f) The rate is 10% for interest paid by enterprises engaging in industrial under takings (manufacturing, assembling and processing, construction, civil engi neering and shipbuilding, production of electricity, hydraulic power, gas or the supply or water, or fishing) to financial institutions.
(g) Payments received as consideration for the use of, or the right to use, indus trial, commercial or scientific equipment constitute business profits (that is, not royalties).
(h) The rate is 7.5% for interest paid to financial institutions.
(i) In certain circumstances, the reduced rates or exemptions do not apply to royalties for copyrights of literary or artistic works, including cinemato graphic films and films or tapes for radio or television broadcasting. Reference should be made to the applicable tax treaty.
(j) The 10% rate applies to payments relating to patents, designs or models, plans, secret formulas or processes, or industrial, commercial or scientific equip ment or information concerning industrial, commercial or scientific experi ence. The 15% rate applies in all other cases.
(k) In the case of Singapore, royalties approved under the Economic Expansion Incentives (Relief from Income Tax) Act are exempt.
(l) The term “royalties” excludes royalties with respect to the operation of mines or quarries or the exploitation of natural resources. A contracting state may exempt or reduce the tax on industrial royalties in accordance with its domes tic laws.
(m) The 5% rate applies if the interest is received by a bank or financial institution.
(n) The double tax agreement between Singapore and Taiwan does not contain an interest article.
(o) The 5% rate applies to payments relating to patents, designs or models, plans, secret formulas or processes, or industrial, commercial or scientific equipment or information concerning industrial, commercial or scientific experience.The 10% rate applies in all other cases.
(p) The lower rate applies to royalties paid for the use of, or the right to use, industrial, commercial or scientific equipment.
(q) The tax rate on royalties in the recipient’s country is limited to 20%.
(r) The 10% rate applies to interest arising in the Philippines with respect to the public issuance of bonds, debentures or similar obligations and paid by a company that is a resident of the Philippines.
(s) In the case of the Philippines, the 15% rate applies to royalties paid by enter prises registered with the Philippine Board of Investments (BOI) and engaged in preferred activities. It also applies to royalties paid with respect to cinematographic films or tapes for television or broadcasting. The 25% rate applies in all other cases, except for those covered by footnote (k).
(t) The 15% rate applies to payments relating to copyrights of scientific works, patents, trademarks, designs or models, plans, secret formulas or processes, industrial, commercial or scientific equipment or information concerning industrial or scientific experience. The 20% rate applies to copyrights of liter ary or artistic works, including cinematographic films or tapes for television or broadcasting.
(u) The 0% withholding tax rate does not apply to persons incorporated under the International Companies Act if their income or profits are not taxed at the normal rate of corporate income tax in Mauritius or any income tax comparable thereto.
(v) Under the protocol to the treaty that provides for a rate reduction on interest if a future treaty signed between Thailand and another state establishes a lower rate, the withholding tax rate applicable to interest is reduced to 10% (or exempt under certain specified circumstances).
(w) The rate also applies to payments for the use of, or the right to use, industrial, commercial or scientific equipment, which includes transport vehicles for cargo transportation.
(x) The rates are three-tiered, which vary according to the nature of the pay ment.
(y) The 5% rate applies to royalties paid for the use, or the right to use, copy rights of literary, artistic or scientific works, including cinematographic films, or films or tapes used for radio or television broadcasting. The rate is 8% if the royalties are for the use of, or right to use, patents, trademarks, designs or models, plans, secret formulas or processes, or industrial, com mercial or scientific equipment. The 10% rate applies in all other cases.
(z) This double tax treaty entered into force on 3 December 2021 and is effec tive from 1 January 2022.
(aa) The exemption applies to interest paid to the following:
• The government of the other contracting state that is the beneficial owner of the interest
• A financial institution of the other contracting state that is the beneficial owner of the interest
• A company (other than a partnership) that is a resident of the other con tracting state and that is the beneficial owner of the interest, if the interest is paid by a company that is a resident of the first-mentioned contracting state
• A resident of the other contracting state that is the beneficial owner of the interest, if the interest is paid with respect to a loan, debt-claim or credit that is guaranteed or insured by the government of either contracting state
The 10% rate applies to other interest.
(bb) The term “royalties” excludes payments of any kind received as a consider ation for the use of, or the right to use, the following:
• Computer software if the payments do not constitute payments for the right to commercially exploit such computer software by reproducing, modifying or adapting the computer software for the purpose of distribu tion or sale or by preparing derivative works based on the computer soft ware for the purpose of distribution or sale
• Any digital content on any media for reproduction or transmission if the payments do not constitute payments for the right to commercially exploit such digital content by reproducing, modifying or adapting the digital content for the purpose of distribution or sale or by preparing derivative works based on the digital content for the purpose of distribution or sale
(cc) The term “royalties” does not include payments for the use of, or the right to use, industrial, commercial or scientific equipment.
(dd) Payments for computer software are royalties only if such payments are made for the right to use and exploit the copyright in the program.
(ee) The 5% rate applies to royalties paid for the use of, or the right to use, copyrights of literary, artistic or scientific works, including cinematographic films, or films or tapes used for radio or television broadcasting. The rate is 10% in all other cases.
(ff) This double tax treaty entered into force on 1 December 2021 and is effec tive from 1 January 2022.
(gg) The term “royalties” excludes royalties with respect to the operation of mines or quarries or the exploitation of natural resources, or for the use of, or the right to use, motion picture films, tapes for use in connection with radio broadcasting or films or video tapes for use in connection with televi sion.
(hh) The protocol to the treaty provides for a rate reduction on interest and/or royalties if a future treaty between Kazakhstan and another state establishes lower rates.
(ii) The 10% rate applies if the beneficial owner is a bank and if the loan has been granted for at least five years for the financing of the purchase of equipment or of investment projects. The protocol to the treaty provides for a rate reduction on interest if a future treaty between Brazil and any other jurisdiction, excluding any jurisdiction in Latin America, establishes lower rates.
(jj) The 15% rate applies to royalties arising from the use or the right to use trademarks. The 10% rate applies to other royalties, which includes pay ments of any kind received as consideration for the rendering of technical assistance.
(kk) The exemption does not apply to royalties received as consideration for the use of, or the right to use, copyrights of literary or artistic works, including cinematographic films and tapes for television or broadcasting or for infor mation concerning commercial experience.
(ll)
The 8% rate applies to royalties received for the use of, or the right to use, industrial, commercial or scientific equipment, or for information concern ing industrial, commercial or scientific experience. The 10% rate applies to royalties received for the use of, or the right to use, copyright of literary, artistic or scientific works, including cinematographic films, films or tapes used for radio or television broadcasting, patents, trademarks, designs or models, plans, secret formulas or processes.
(mm) This double tax treaty entered into force on 30 December 2021 and is effec tive from 1 January 2022.
(nn) The protocol to the treaty provides for a rate reduction on interest and/or royalties if a future treaty between Nigeria and any other jurisdiction estab lishes lower rates.
(oo) This double tax treaty entered into force on 16 August 2021 and is effective from 1 January 2022.
(pp) The 5% rate applies to royalties received for the use of, or the right to use, copyrights of literary, artistic or scientific works, including software, cine matographic films, or films, tapes or recordings used for radio or television broadcasting. The 10% rate applies to royalties received for the use of, or the right to use, patents, trademarks, designs or models, plans, secret formulas or processes, for the use of, or the right to use, industrial, commercial or scientific equipment or for information concerning industrial, commercial or scientific experience.
(qq) The term “royalties” excludes any royalties or other amounts paid with respect to literary or artistic copyrights, copyrights of motion picture films or of tapes for television or broadcasting or for the operation of a mine, oil well, quarry or any other place of extraction of natural resources.
(rr) The term “royalties” includes payments of any kind received in consider ation for technical services. The 5% rate applies to payments of any kind received in consideration for technical services. The 10% rate applies to payments of any kind received in consideration for the use of, or the right to use, copyrights of literary, artistic or scientific works, including cinemato graphic films; films or tapes for radio or television broadcasting; computer software, patents, trademarks, designs or models, plans, secret formulas or processes, for the use of, or the right to use, industrial, commercial or scien tific equipment or for information concerning industrial, commercial or scientific experience.
(ss) The protocol to the treaty provides for a rate reduction on interest if a future treaty between Uruguay and any other jurisdiction establishes lower rates.
(tt) The protocol to the treaty provides for a rate reduction on interest if a future treaty between Vietnam and any other state establishes lower rates.