Guide on Singapore Corporate Taxation

Singapore has been consistently ranked as one of the most business-friendly economies year after year by World Bank. Many factors have contributed to Singapore’s competitive edge: easy access to capital, strategic location, excellent infrastructure, ease of doing business etc. And one prominent factor is Singapore’s tax-friendliness.

Overview

In Singapore, income accrued in or derived from Singapore and income received in Singapore from overseas are taxable. IRAS assesses the amount of tax based on the income earned by the company in the preceding financial year. In other words, the income earned in the financial year 20X8 will be taxed in 20X9, which is referred to as Year of Assessment (YA) 20X9.

With effect from 2010, all companies are taxed at a flat rate of 17% on its chargeable income i.e. taxable revenues less tax-allowable expenses. In addition to the competitive tax rate, Singapore government offers incentives, subsidies and schemes which lower the effective tax payable further.

Here are some of the tax schemes available to lower the tax payable:

I) Tax Exemption Scheme for New Start-Up Companies

To promote entrepreneurship and support the growth of local enterprises, this scheme was introduced in YA 2005. This is available to all new companies except investment holding companies and companies engaged in development of properties.

To be eligible for this scheme, companies must satisfy the following qualifying conditions:

1. Incorporated in Singapore;
2. Tax resident in Singapore for that YA;
3. Have no more than 20 shareholders throughout the basis period for that YA where:
   • all of the shareholders are individuals; or
   • at least one shareholder is an individual holding at least 10% of the issued ordinary shares of the company.

Qualifying companies can enjoy 75% exemption on the first $100,000 chargeable income and a further 50% exemption on the next $100,000 chargeable income for the first three consecutive YAs.

II) Partial Tax Exemption for Companies (PTE)

From the fourth YA onwards, companies can enjoy the partial tax exemption.

All companies can enjoy PTE, unless they have already claimed the Tax Exemption Scheme for New Start-Up Companies. Qualifying companies can enjoy:

• 75% tax exemption on the first $10,000 of chargeable income; and
• A further 50% tax exemption on the next $190,000 of chargeable income.

III) Corporate Income Tax Rebate

All companies (including Registered Business Trusts, non-resident companies that are not subjected to final withholding tax and companies with income taxed at a concessionary tax rate) are granted corporate income tax rebates year on year.

IV) Double Tax Deduction for Internationalisation (DTDi)

This allows the companies to claim tax deductions on eligible costs relating to overseas market expansion, development, and internationalisation.

V) Tax Breaks on Foreign Income

With the increase of globalisation, it is not surprising that many tax-resident companies in Singapore are deriving income from overseas. Such income (referred to as foreign income) is taxable in Singapore when remitted to and received in Singapore, which may result in double taxation – once in the foreign country, and a second time when the foreign income is remitted into Singapore.

To alleviate the double taxation suffered, resident companies may claim the following:

Foreign Tax Credit (FTC)

Under FTC, companies may claim credits for the foreign tax paid against the Singapore tax payable on the same income. There are two ways to claim:

• Unilateral tax credit (UTC) – This is for income remitted from countries which Singapore does not have a Double Taxation Agreement (DTA) with; or
• Double taxation relief (DTR) – This is for income remitted from countries which Singapore has a DTA with.

Tax Exemption of Foreign-Sourced Income (FSIE)

Under FSIE, a Singapore tax-resident company can enjoy tax exemption on specified foreign income (i.e. foreign-sourced dividends, foreign branch profits and foreign-sourced service income) provided that the following conditions are met:

• The headline corporate tax rate of the foreign country from which the income is received is at least 15%;
• The foreign income has been subjected to tax in the foreign country; and
• The Comptroller is satisfied that the tax exemption would be beneficial

FTC Pooling System

Introduced in 2011, the FTC Pooling system provides greater flexibility to businesses in their FTC claims, reduces the tax payable in Singapore on remitted foreign income and simplifies tax compliance. Under this system, resident companies may elect to aggregate the foreign taxes paid.

To be eligible:

• The headline corporate tax rate of the foreign country from which the income is received is at least 15%;
• Foreign income tax is paid on the income in the foreign country from which the income is derived;
• The company is entitled to claim FTC under the Income Tax Act; and
• There is tax payable on the foreign income in Singapore.

VI) Tax Residency of Company

The basis of taxation is generally the same for resident and non-resident companies. However there are certain benefits that are available to resident companies only.

Some of the benefits include:

• Tax benefits under DTA concluded between Singapore and treaty countries;
• FSIE; and
• Tax exemption for new start-up companies.

To determine the tax residency of a company, the location where the business is controlled and managed will be looked at. This would mean that a company is a tax resident in Singapore when the control and management of the company is exercised in Singapore.

VII) Withholding Tax on Non-Resident Companies

For non-resident companies, when payment of a specified nature (e.g. interest, commission, fee in connection with any loan or indebtedness; royalty etc.) is made to them, tax must be withheld.

The rate of withholding tax depends on the nature of payment. For example, 15% has to be withheld for payment of interest derived by non-resident companies through operations carried on outside Singapore.

---

Disclaimer: This guide is intended as a general guide only, and the application of its contents to specific situations will depend on the particular circumstances involved. Accordingly, readers should seek appropriate professional advice regarding any particular tax issue that they encounter, and this guide should not be relied on as a substitute for this advice. While all reasonable attempts have been made to ensure that the information contained in this guide is accurate, Enston accepts no responsibility for any errors or omissions it may contain, whether caused by negligence or otherwise, or for any losses, however caused, sustained by any person that relies on it.

---