print friendly version
Text Size  A  A  A

For companies

What is a COR
Why do I need a COR
Who can apply
How to apply
When will I receive the COR

What is a COR

A COR is a letter certifying that the company is a tax resident in Singapore for the purpose of claiming benefits under the Avoidance of Double Taxation Agreement (DTA).

A company is a tax resident in Singapore if the control and management of its business is exercised in Singapore. A Singapore tax resident company can enjoy the benefits in the DTAs that Singapore has concluded with other treaty countries.

Why do I need a COR

You need a COR to enjoy the benefits under the DTAs that Singapore has concluded with other treaty countries.

When your company derives income from a foreign person or company, you may be subject to taxes in that foreign country. However, if the foreign country has concluded a DTA with Singapore, the DTA may allow Singapore tax residents to enjoy a reduced tax rate or an exemption of tax on the income in that foreign country.

To enjoy this benefit, you have to submit a COR to the foreign tax authority to prove that your company is a Singapore tax resident.

Who can apply

  • You can apply only if your company is a tax resident in Singapore. The application is for back Years of Assessment (YA), the current YA or the next YA.
  • The income is remitted or going to be remitted into Singapore.
  • This is not applicable to:
    1. A nominee company as it is not the beneficial owner of the income derived from the treaty country. A nominee company is a company that is formed for the purpose of holding shares on behalf of the beneficial owners of the shares.
    2. A foreign-owned* company which is an investment-holding company with purely passive sources of income or receiving only foreign-sourced income.

      However, COR may be issued provided that such a company can furnish the reasons for setting up an office in Singapore and provide evidence to substantiate that its control and management is in Singapore. In particular, IRAS considers the following factors:

      a) Board of directors’ meetings are held in Singapore even if decisions made pertain only to routine matters since the company is an investment holding company, and
      i) Presence of other related companies (tax resident or with business activities) in Singapore; or
      ii) Receives support or administrative services from a related company in Singapore; or
      iii) Have at least 1 director based in Singapore who holds an executive position and is not a nominee director; or
      iv) Have at least 1 key employee (e.g. CEO, CFO, COO) based in Singapore.
    3. A non-Singapore incorporated company or the Singapore branch of a non-Singapore incorporated company since the control and management of the Singapore branch is vested with the overseas parent company. COR may be issued if IRAS is satisfied that the control and management of the company is indeed exercised in Singapore and there are valid reasons as  to why the company is not incorporated in Singapore.
  • IRAS reserves the right to request for additional information on the company.

* A foreign-owned company refers to a company where 50% or more of its shares are held by foreign companies/shareholders.

How to apply

Companies can apply for a COR either:

When will I receive the COR

The fastest way to obtain a COR is to apply for it online via myTax Portal. To learn how to do so, you may refer to the user guides for COR.

Online COR applications via myTax Portal


We will process your application within 7 working days.

However, if you have submitted a paper application for COR, we will inform you within 14 working days from the day we receive the duly completed and signed application form.


FAQs

 
Yes, companies can request duplicate CORs by applying for them again via myTax Portal – there is no fee for this service.
 
If companies submit their request for duplicate CORs by paper application, a fee will be charged on cost-recovery basis (refer to table below for details). Payment can be made via NETS or Cashcard upon collection of documents.
 
Fees for document request

 Year of Assessment which the document relates to  Search fee  Fees for uncertified documents
(for each page of document)
 Fees for  certified documents
(for each page of document)
More than six years before the current year $36.00 for the seach of each document $0.30 per page $3.00 per certified page
Six years or less before the current year $12.00 for each search of documents $0.30 per page $3.00 per certified page

 

 

 

 

 

 

 

Rate this page
Strongly Disagree                 Strongly Agree
Information is easy to understand.  
Information is useful.
Information is easy to find.

Suggestions to improve this page:
  
Please email us if you would like us to respond to your enquiries.

Last Updated on 3 April 2014


© 2014 Inland Revenue Authority of Singapore. All Rights Reserved.