2017新加坡税务简报（英文版）

Singapore International Tax Highlights 2017 Summary

Core Content Overview

Singapore's tax system is designed to be competitive and attractive for both corporate and individual taxpayers, with a focus on simplicity, transparency, and international alignment. The following summary outlines the key aspects of Singapore's international tax framework as of 2017.

Corporate Taxation

Tax Basis and Residence

• Territorial Basis: Singapore taxes income accrued in or derived from Singapore, including foreign income remitted or deemed remitted to Singapore.
• Residence: A company is considered a Singapore tax resident if its management and control are exercised in Singapore, typically where directors' meetings are held.

Taxable Income

• Includes gains from trade, dividends, interest, rent, royalties, and other profits from property.
• Exemptions: Foreign-source dividends received in Singapore are taxable unless certain conditions are met. However, dividends from Singapore resident companies are tax-exempt in the hands of the recipient.
• Capital Gains: Not taxed in Singapore. However, gains from the sale of shares may be treated as ordinary income if the taxpayer is in the business of trading in shares.

Tax Rates

• Standard Corporate Tax Rate: 17%
• Exemptions: 75% of the first SGD 10,000 and 50% of the next SGD 290,000 of normal chargeable income are exempt.
• Exempt Private Companies: May be exempt on the first SGD 100,000 and 50% of the next SGD 200,000 of normal chargeable income for the first three consecutive years of assessment (subject to conditions).

Deductions and Exemptions

• Deductible Expenses: Revenue-related expenses, capital allowances, and tax losses from prior years.
• Foreign Income Remittances: Exempt from tax if the foreign source has a headline tax rate of at least 15%, and the income has been taxed abroad.
• Foreign Tax Credit: Available for foreign taxes paid on income from treaty and nontreaty countries, limited to the lower of the foreign tax paid or the Singapore tax payable on that income.

Withholding Taxes

• Dividends: No withholding tax on dividends paid by Singapore resident companies.
• Interest: 15% withholding tax on interest paid to nonresidents, unless reduced by a tax treaty or domestic concession.
• Royalties: 10% withholding tax on royalties paid to nonresidents, unless reduced by a tax treaty or domestic concession.
• Technical Service Fees: 17% withholding tax on payments to nonresidents (other than individuals) for technical services, unless reduced by a tax treaty.

Personal Taxation

Tax Basis and Residence

• Resident Individuals: Subject to tax on income accrued in or derived from Singapore. Foreign-source income received in Singapore is taxable, except for certain investment income.
• Nonresident Individuals: Taxed only on income from Singapore, including employment income, directors' fees, and consultants' fees.

Taxable Income

• Includes income from trade, business, profession, and employment.
• Capital Gains: Not taxed.
• Employment Income: Nonresidents are taxed at the higher of 15% flat rate or resident tax rates (with personal reliefs and rebates).

Tax Rates

• Residents: Progressive rates from 2% to 22% for income above SGD 20,000 (effective from YA2017).
• Nonresidents: Flat rate of 22% on most income, or 15% on short-term employment (≤60 days).

Deductions and Allowances

• Personal reliefs and tax rebates are available only to resident individuals.
• Nonresidents do not receive personal deductions or allowances.

Other Taxes

Real Property Tax

• Applicable to: Immovable property (residential and non-residential).
• Rates: 0% to 16% for owner-occupied residential, 10% to 20% for non-owner-occupied residential, and 10% for non-residential.
• Exemptions: May apply to land under development.

Stamp Duty

• Applicable to: Financial instruments (stock, shares) and immovable property.
• Residential Property: Buyer's Stamp Duty (BSD) ranges from 1% to 3%, with additional Buyer's Stamp Duty (ABSD) from 5% to 15% depending on the buyer's category.
• Non-residential Property: 10% rate.
• Exemptions: Apply to leases with annual rent ≤ SGD 1,000 and certain transactions.

Social Security

• CPF Contributions: Required for Singapore citizens and permanent residents, with employer and employee contributions up to 17% and 20%, respectively.

Compliance and Anti-Avoidance

Tax Year

• Corporate tax year is the financial year, while personal tax year is the calendar year.

Filing Requirements

• Corporations: Must submit estimated chargeable income within three months of financial year end. Tax returns are due by 30 November or 15 December of the year of assessment.
• Individuals: Tax returns must be filed by 15 April or 18 April (electronic) of the following year.

Penalties

• Apply for late filing and failure to file.

Anti-Avoidance

• General Anti-Avoidance Rule: Available to counteract tax avoidance strategies.
• Transfer Pricing: Guidelines apply to ensure transactions between related parties are at arm's length.
• Thin Capitalization: Not applicable.
• Controlled Foreign Companies (CFCs): Not applicable.

Tax Treaties and Authorities

• Tax Treaties: Singapore has 81 comprehensive tax treaties.
• Tax Authorities: Inland Revenue Authority of Singapore (IRAS).
• Tax Law Sources: Income Tax Act, Property Tax Act, Stamp Duties Act, Goods & Services Tax Act, and Economic Expansion Incentives (Relief from Income Tax) Act.

Goods and Services Tax (GST)

• Taxable Transactions: Most goods and services and imports.
• Rates: Standard rate of 7%, zero rate for international services and exports.
• Exemptions: Financial services, residential property sales/leases, and investment precious metals.
• Registration: Required if taxable turnover exceeds SGD 1 million in a 12-month period. Voluntary registration is allowed.
• Filing and Payment: Quarterly GST returns, with the option to file semi-annually or monthly. Tax must be paid by the submission deadline. Refunds are typically received within three months.

Contact Information

• Deloitte: Low Hwee Chua (hwlow@deloitte.com)
• Disclaimer: This document provides general information and does not constitute professional advice. Readers should consult qualified professionals for tax-related decisions.