For international businesses with operations in or through Singapore, proper tax planning and advice are highly recommended. Singapore currently has over 100 double taxation agreements ('DTAs') effectively in place and continues to expand its network through active negotiations with additional jurisdictions.
Moreover, Singapore's extensive network of international tax agreements — including its Tax Information Exchange Agreements with multiple jurisdictions — underscores the importance of identifying tax risks and exposures proactively. As global transparency standards tighten, understanding your cross-border obligations has become essential.
We advise on a wide range of international tax matters, including:
We also prepare and file corporate and individual tax returns and computations to meet statutory requirements:
A Certificate of Residence (COR) is a letter issued by the Inland Revenue Authority of Singapore (IRAS) to certify that a company is a tax resident of Singapore. It is used to claim tax benefits under Singapore's Avoidance of Double Taxation Agreements (DTAs), such as reduced withholding tax rates or exemptions on foreign income. The COR must be submitted to the relevant foreign tax authority as proof of Singapore tax residency. Singapore's standard non-treaty withholding tax rates are 0% on dividends, 15% on interest, and 10% on royalties; DTAs may provide further reductions.
Obtaining a Certificate of Residence (COR) from IRAS is not always straightforward, particularly for companies. IRAS considers various factors when assessing an application. In general, the more management and control functions—and substance—a company maintains in Singapore, the stronger its case for securing a COR.
Our Singapore tax professionals can advise on strengthening your application for a Certificate of Residence (COR) from IRAS and assist with the entire application process, including responding to IRAS enquiries. Beyond completing the necessary forms, we help applicants present additional supporting information, documents, and legal arguments where appropriate to improve the likelihood of obtaining the COR.
Singapore adopts a territorial basis of taxation. All individuals, whether resident or non-resident of Singapore, are subject to Singapore tax on Singapore-sourced income.
Singapore adopts a territorial basis of taxation. All individuals, whether resident or non-resident of Singapore, are subject to Singapore tax on Singapore-sourced income.
An individual is regarded as a Singapore tax resident if he/she (a) is a Singapore citizen or permanent resident residing in Singapore, or (b) is a foreigner who has stayed or worked in Singapore for 183 days or more in the calendar year preceding the year of assessment.
A company is regarded as a Singapore tax resident if its control and management of its business is exercised in Singapore. This generally means that the company's board of directors meets and makes strategic decisions in Singapore, and key management functions are carried out here. Incorporation in Singapore alone does not automatically confer tax residency status.
Singapore has entered into Avoidance of Double Taxation Agreements (DTAs) with over 100 jurisdictions to prevent double taxation and fiscal evasion, and to foster cooperation between Singapore and other international tax administrations in enforcing their respective tax laws. A list of the comprehensive double taxation agreements currently concluded can be found on the Inland Revenue Authority of Singapore's website at www.iras.gov.sg.
A Certificate of Residence is a document issued by the Inland Revenue Authority of Singapore to a Singapore tax resident who requires proof of resident status for the purpose of claiming tax benefits under the Avoidance of Double Taxation Agreements.
Notably, Singapore does not have a comprehensive tax treaty with the United States.
Singapore's transfer pricing framework has been in place for many years and was significantly enhanced with the introduction of detailed transfer pricing guidelines and documentation requirements. Singapore's transfer pricing laws follow the arm's length principle and the guidelines set forth by the Organisation for Economic Co-operation and Development (OECD) to combat base erosion and profit shifting and to ensure fair tax competition among jurisdictions.
The determination of corporate residence is important for the purpose of an Avoidance of Double Taxation Agreement (DTA). Whether a foreign corporation is carrying on a trade, profession, or business in Singapore and the source of profits are the decisive factors when determining taxability. For this purpose, if a foreign corporation has a permanent establishment (PE) in Singapore, it will be deemed as carrying on a trade, profession, or business in Singapore.
A permanent establishment is a fixed place of business through which the activities of a company are carried on, including a branch, office, or place of management. In addition, a company is regarded as having a permanent establishment in Singapore if it has an agent who habitually exercises authority to conclude contracts or carries on certain activities in Singapore on its behalf.
The Inland Revenue Authority of Singapore (IRAS) can exchange information with another country's tax authority in two ways: (i) Automatic Exchange of Financial Account Information, in which information is exchanged automatically between tax authorities under the Common Reporting Standard (CRS) based on the OECD model; and (ii) Avoidance of Double Taxation Agreements (DTAs) and Tax Information Exchange Agreements (TIEAs), in which information is exchanged manually upon request between tax authorities.
Following the Base Erosion and Profit Shifting (BEPS) Action 13 developed by the Organisation for Economic Co-operation and Development (OECD), Singapore's transfer pricing framework provides for the preparation of transfer pricing (TP) documentation under a three-tiered approach, for the purpose of facilitating TP risk assessment and transparency of tax information. The three-tiered approach includes the following:
A Singapore entity is required to prepare and maintain the above TP documentation and file it with IRAS by the prescribed deadline if the exemption criteria are not met. Failure to comply with the requirements may result in penalties imposed by IRAS.
Our international tax professionals can navigate through the complex TP rules and regulations, and provide the following tailor-made services:
The BVI has introduced the Economic Substance (Companies and Limited Partnerships) Act, 2018, under which prescribed entities in the BVI carrying out certain types of business activities are required to maintain economic substance in the BVI.
The business activities subject to the economic substance requirements include but are not limited to investment holding business, intellectual property holding business, and headquarters business. The substance required to be maintained in the BVI includes but is not limited to physical office and assets, employees, management, and core income-generating activities.
Having said that, if a BVI entity is a tax resident in another foreign tax jurisdiction (which is not a black-listed jurisdiction), supported by documentary evidence such as a Certificate of Residence issued by the competent authority of the relevant foreign tax jurisdiction, it may potentially not be subject to the substance requirements in the BVI.
BVI entities are obliged to provide prescribed information annually to their registered agents in the BVI for reporting to the BVI government authorities. The specific reporting periods and deadlines are determined by the BVI International Tax Authority and are subject to change.
Our international tax experts can provide the following services:
Based in Singapore, HKWJ Tax Consultants Pte. Ltd. makes getting started simple. Tax compliance, accounting, incorporation, business support — our team tailors every solution locally, handled with the discretion and care you expect. Contact us to see how we can support your goals.
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