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Withholding tax (for payment to non-residents or non-resident companies)

Nature of Income Tax rate
Interest, commission, fee or other payment in connection with any loan or indebtedness 15% 1
Royalty or other lump sum payments for the use of movable properties 10% 1 2

Payment for the use of or the right to use scientific, technical, industrial or commercial knowledge or information

10% 1 2
Rent or other payments for the use of movable properties 15% 1
Technical assistance and service fees Prevailing Corporate Tax rate 3
Management fees Prevailing Corporate Tax rate 3
Time, voyage and bareboat charter fees for the charter of ships NIL
(Tax rates for payments due and payable before 17 Feb 2012) 
Time charter fees and voyage charter fees for the charter of aircraft  
(a) Paid to a resident of a tax treaty country who is an aircraft operator claiming benefits under the "Shipping and Air Transport" Article of the tax treaty and where the Article provides for:  
  • Full exemption of shipping and aircraft profits
 
NIL
  • 50% exemption of shipping and aircraft profits
 
1%
  • Reduced rate
 
Reduced rate or 2% whichever is the lower
(b) Paid to a resident of a tax treaty country who is not an aircraft operator (i.e. the "Shipping and Air Transport" Article of the treaty does not apply) 2%
(c) Paid to a resident of a country which has no tax treaty with Singapore 2%
Bareboat charter fees for the charter of aircraft  
(a) Paid to a resident of a tax treaty country who is an aircraft operator claiming benefits under the "Shipping and Air Transport" Article of the tax treaty and where the Article specifically covers bareboat charter fees and provides for:  
  • Full exemption of shipping and aircraft profits
 
NIL
  • 50% exemption of shipping and aircraft profits
 
1%
  • Reduced rate
 
Reduced rate or 2% whichever is the lower
(b) Paid to a resident of a tax treaty country who is not an aircraft operator (i.e. the "Shipping and Air Transport" Article of the treaty does not apply) or where the "Shipping and Air Transport" Article does not cover bareboat charter fees 2% (unless it is further reduced by other provision of the tax treaty such as the "Royalty" Article)
(c) Paid to a resident of a country which has no tax treaty with Singapore 2%
Proceeds from sale of any real property by a non-resident property trader 15%
Distribution of taxable income made by REIT to unitholder who is a non-resident (other than an individual)
10% 4
1 These withholding tax rates apply when the income is not derived by the non-resident person through its operations carried out in Singapore. They are to be applied on the gross payment and the resultant tax payable is a final tax. For operations carried out in Singapore, the tax rates applicable on the gross payment are as follows:

2 The reduced withholding tax rate of 10% applies to payments due and payable on or after 01 Jan 2005.

3 If the year in which the services were rendered is different from the year of payment, the withholding tax is to be based on the prevailing corporate tax rate for the year where the services were rendered. For example, if the service was rendered in Dec 2008 and the payment was made in year 2009, the prevailing corporate tax is that for year 2008 (Year of Assessment 2009), which is 18%.
For payments made to non-resident individuals, tax is to be withheld at 20% on the gross payment.

4 The reduced withholding tax rate of 10% applies to distributions made during the period from 18 Feb 2005 to 31 Mar 2015 (Budget 2005 and Budget 2010 refer). With effect from 16 Feb 2007, withholding tax shall not apply to any distribution made by the trustee of the REIT where tax has been paid by the trustee of the trust on the income from which the distribution is made (Income Tax (Amendment) Act 2007 refers).

In the situation where tax has been deducted in error at the prevailing corporate tax rate from the distributions made to nominees whose beneficiaries are any of the persons^ listed below, the Comptroller will refund the tax over-deducted to the trustee of REIT directly on a quarterly basis:
- qualifying individual;
- qualifying non-resident non-individual;
- charity registered under the Charities Act (Cap. 37) or established by any written law;
- town council;
- statutory board;
- co-operative society registered under the Co-operative Societies Act (Cap. 62); or
- trade union registered under the Trade Unions Act (Cap. 333).


^ Do not include a person acting in the capacity of a trustee New!

The trustee is required to send its request for refund with the original subsidiary income tax certificates on a consolidated basis to:

Revenue Accounting Branch
Inland Revenue Authority of Singapore
55 Newton Road
Revenue House
Singapore 307987

Where an Avoidance of Double Taxation Agreement (DTA) is applicable, the rates specified in the DTA of the respective countries would apply. If you are applying the rates in the DTA, you would need a Certificate of Residence from the non-resident to prove that it is a tax resident of the treaty country. Please submit a Certificate of Residence from Non-Residents (Claim for relief from Singapore Income Tax under Avoidance of Double Taxation Agreement) that is duly certified by the tax authority of the country of residence, to IRAS.

Download the template of Format for Certificate of Residence (COR) from Non-Residents (289KB).

 

 

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Last Updated on 13 December 2013


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