Singapore has one of the most competitive tax regimes in the world and a number of interesting tax incentive schemes to attract investors. However, any research prior to where to establish a business operations would not be complete without a thourough investigation of the tax impact. This should reflect the following:
the tax aspects of the investor's home country
the tax aspects in the country where the investment is made
how the above tax regimes interact
the tax impact to the individual taxation of executives
Singapore adopts a 'territorial' basis of taxation, i.e. companies and individuals are taxed on Singapore sourced income. Foreign source (‘offshore' ) income is not taxable until received in or remitted into Singapore.
Tax exemption applies on foreign-sourced dividends, foreign branch profits, and foreign-sourced service income of the following conditions are met:
The headline tax rate of the foreign country from which the income was received is at least 15%
The foreign income was subject to tax in the foreign country from where it was received
A company is a tax resident of Singapore if the control and management of its business is exercised in Singapore. Foreign income earned by a Singapore company may be subjected to taxation twice - once in the foreign country, and a second time when the foreign income is remitted into Singapore.
Singapore has signed several Double Taxation Agreements (DTA) which serve to relieve double taxation of income and provide for reduction or exemption of tax on certain types of income.
Pioneer Scheme for Manufacturing or Services provides tax exemption on income from qualifying activities - suitable for Manufacturing, Services, GHQ
Development and Expansion Incentive provides reduced tax 5% or 10% on incremental income from qualifying activities - suitable IP Hub, Manufacturing, Service,s RHQ/IHQ*
Investment Allowance provides allowance of 30% or 50% of approved fixed capital expenditure on top of normal 100% capital allowance - suitable for Manufacturing
Approved Holding Company Status provides certainty of capital gains treatment for disposal of approved subsidiaries of at least 50% shares held for at least 18 months - suitable for RHQ/IHQ with holding function
RHQ/IHQ with holding function provides reduced tax 5% or 10% on fees, interest, dividends and gains from qualifying services/activities and Withholding Tax Exemption on interest payments on loans from banks and network companies for Finance and Treasure Center activities - suitable for Finance and Treasure Center
Approved Royalties Incentive provides reduced WHT 0% or 5% on royalty payments to access advanced technology and know-how -suitable for Finance and Treasury Centers and Manufacturing
Approved Foreign Loan provides reduced WHT 0% or 5% on royalty payments to access advanced technology and know-how - suitable for Manufacturing
S19B writing-down allowances for IP acquisition provides automatic 5-year write-down if legal and econ IPR are acquired EDB's approval is required if only econ IPR is acquired - suitable for IT Hub
S19C writing-down allowances for R&D cost-sharing provides 1-year write-down for R&D cost-sharing payments - suitable for Manufacturing and IT Hub
* Regional Head Quarter, International Head Quarter