Provision of Service to Overseas Customer

1

(a) Media Sales

Place of circulation is substantially outside Singapore

S21(3)(u)

Webpage on Advertising services

GST: Treatment of Advertising Services (295KB)

(b) Media Planning

Services are provided contractually to and directly benefiting overseas person

S21(3)(j)

(c) Creative and Production Sales

Services are provided contractually to and directly benefiting overseas person

S21(3)(j)

(d) Brand Public Relations

Services are provided contractually to and directly benefiting overseas person

S21(3)(j)

(e) Event Organising

Event is held wholly outside Singapore; or
Services are provided contractually to and directly benefiting overseas person in his business capacity

S21(3)(i);S21(3)(k)

2

Co-location service in Singapore of computer server equipment (i.e. providing a physical environment for the operation of computer server equipment)

Services supplied:

1. under a contract with an overseas person ; and
2. which directly benefits an overseas person .

S21(3)(s)

GST Treatment of Web-Hosting Services and Server Co-location Services (253KB)

3

International transport of passengers

Passengers must be transported:

1. from Singapore to a place outside Singapore;
2. from a place outside Singapore to Singapore; or
3. from a place outside Singapore to another place outside Singapore.

From 1 Jul 2010, the international transport of passengers by sea qualifies for zero-rating:

1. where the transporting vessel is bound for or returning from a fixed port of call outside Singapore, including
   • from a place outside Singapore to another place outside Singapore;
   • from a place in Singapore to a place outside Singapore; or
   • from a place outside Singapore to a place in Singapore.
2. where the transporting vessel sails to or from international waters and the course of transportation occurs "substantially outside of Singapore".

3. A course of transportation is considered "substantially outside Singapore" if travel in Singapore waters is only needed for departing to or returning from international waters.

S21(3)(a)

You are a local travel agent. Your customer buys a single air ticket for flights from Singapore to Japan and then to Los Angeles.

You may charge GST at 0% on the air tickets because it is a contract for international transport.

From 1 Jul 2010, "cruise-to-nowhere" packages, (i.e. cruises in international waters which do not dock at any port outside Singapore), will qualify for zero-rating.

GST: Travel Industry (150KB)

4

International transport of goods; and any transport of goods within Singapore (including handling, loading and unloading), being part of the international transport supplied by the same person or agent.

To qualify as international transport, the goods must be transported:

1. from Singapore to a place outside Singapore;
2. from a place outside Singapore to Singapore; or
3. from a place outside Singapore to another place outside Singapore.

From 1 Jul 2010, the international transport of goods by sea qualifies for zero-rating:

1. where the transporting vessel is bound for or returning from a fixed port of call outside Singapore, including
   • from a place outside Singapore to another place outside Singapore;
   • from a place in Singapore to a place outside Singapore; or
   • from a place outside Singapore to a place in Singapore.
2. where the transporting vessel sails to or from international waters and the course of transportation occurs "substantially outside of Singapore".

3. A course of transportation is considered "substantially outside Singapore" if the travel in Singapore waters is only needed for departing to or returning from international waters.

   Zero-rating also applies to the domestic transport of goods within Singapore if it is supplied as part of the international transportation of goods, and it is supplied by the same supplier. The supplier does not need to perform the domestic transport activities himself, but must be contracted to provide both the international and domestic leg of transportation.

   Zero-rating does not extend to domestic transport services provided to passengers.

S21(3)(a);
S21(3)(b)

You provide transport services from a warehouse in Singapore to the airport and then out of Singapore.

You may zero-rate the total value of transportation services (including the local transportation costs) since you are providing both international and domestic transportation services.

GST Guide for the Logistics Service Industry (536KB)

5

Services of the following description:

1. Insuring or arranging for insurance; or
2. Arranging for international transport.

Services must be in relation to the international transport of passengers or goods.

S21(3)(c)

Premiums / commissions for the following types of insurance:

1. Marine cargo, Marine hull
2. Aviation cargo, aviation hull
3. Travel insurance (which is identifiable with journeys involving carriage of passengers or goods to and from Singapore)

GST Guide for the Logistics Service Industry (536KB)

GST: Guide for the Insurance Industry (Third Edition) (199KB)

6

Lease or hire of any type of transport for use outside Singapore throughout the period of lease

The transport is:

1. exported by the lessor to such a place; or
2. already outside Singapore at the time of the supply.

S21(3)(d)

You may zero-rate your leasing services if you lease trucks for use in Johor.

7

Services are any of the following:

1. cultural, artistic, sporting, educational (all forms of instruction), or entertainment (e.g concerts, performance, game, sport) services,
2. exhibition or convention services; or
3. other services supplementary to those listed above. This includes organising the performance outside Singapore.

Services must be performed completely outside Singapore.

S21(3)(i)

An event management company charges a fee for organising a concert in Malaysia.

A management course entirely conducted in Beijing, China.

8

Services performed directly in connection with goods

Services must be directly in connection with goods for export and supplied to an overseas customer, at the time the services are performed.

Services must not include media sales under S21(3)(u).

There must be definite and immediate intention for export at the time the services are performed in order for you to zero-rate your supply under this section.

To establish definite and immediate intention for export, you must satisfy the following requirements - 

• You must obtain a written confirmation from the overseas customer (e.g. from contracts, correspondences) that the goods will be exported after completion of the services and the expected date of export. 
• You have up to 60 days from the completion of service to ensure goods are exported and obtain the required export documents in the e-Tax Guide “GST Guide on Exports”. You need not be the exporter of the goods.

If you are the intermediary service provider (i.e. after you have completed your services, you deliver the goods to another service provider of your overseas customer for further value-added services before the goods are exported), you cannot zero-rate your services to your overseas customer unless you are certain that the goods will be exported.

To establish certainty that the goods will be exported, you must satisfy the following requirements:

• You have written confirmation from your overseas customer that the goods will be exported after another appointed service provider has performed his services and obtain the expected date of export. 
• You know who is your   overseas customer's other service provider (with regard to the particular supply chain).
• You must obtain confirmation from the other service provider that the goods will be exported and obtain a copy of the export documents within 60 days after completion of his services.

S21(3)(g)

You provide engraving services for pewter vases to be exported to Australia. The service is billed to an overseas customer.

You provide domestic transport services to an overseas customer by collecting the goods from a local warehouse and delivering them to the airport for overseas export.

GST Guide for the Logistics Service Industry (536KB)
Clarification on 'Directly in Connection with' and 'Directly Benefit' (474KB)

In order for you and XYZ Pte Ltd to zero-rate the services provided to the overseas customer, both of you must be certain that the machine will be exported (based on written confirmation from the overseas customer) and obtain the expected date of export.

After you provide the repackaging services, you must export the machine and collate all the export documents within 60 days. Both you and XYZ Pte Ltd must maintain copies of the required export documents. XYZ Pte Ltd does not have to be the party to export the goods in order for his services to be zero-rated.

9

Certain financial services supplied in connection with goods.
The full list of services can be found in the First Schedule of GST (International Services) Order. Please refer to paragraph (h) in the extract of Section 21 of the GST Act (207KB).

Services must be in connection with goods for export or goods that are moved from a place outside Singapore to another place outside Singapore (i.e. out-of-scope supplies of goods)

S21(3)(h)

An insurance company provides export credit insurance to company A to protect company A from non-payment by its overseas customer for goods exported.

GST Guide for the Insurance Industry (199KB)

10

Services made directly in connection with land or buildings.

These may include:

1. Services made in the course of construction, repair, and maintenance of any building.
2. Services provided by estate agents, auctioneers, architects, and engineers.

Services must be directly in connection with land or buildings located outside Singapore.
Services must not include media sales under S21(3)(u).

S21(3)(e)

An architect in Singapore provides design services for a building located in China.

An estate agent in Singapore sells a house in London.

GST: Construction Industry (English version) (273KB)

GST and the Construction Industry (Chinese version) (269KB)

11

Services performed directly in connection with goods.

Services must be directly in connection with goods located outside Singapore at the time the services are performed.
Services must not include media sales under S21(3)(u).

S21(3)(f)

A local company provides repair services for a computer network system in Malaysia.

12

Services supplied to overseas persons

The services must be supplied:

• under a contract with an overseas person ; and
• which directly benefit an overseas person

Services must not relate to land or goods in Singapore, other than goods referred to in S21(3)(g).

The overseas person must not be in Singapore at the time the services are performed.

Services must also not include media sales under S21(3)(u).

S21(3)(j)

You provide market research services on 'price of medical services' for an overseas company.

13

Services within the list of prescribed services:

1. Services of engineers, accountants, lawyers and other similar consultancy services;
2. Data processing and provision of information.
3. The testing of a sample of goods that are taken from or form part of:
   • goods outside Singapore at the time the services are performed, or
   • goods for export outside Singapore;
4. Handling, storage at, or transport of goods to or from the place of export to or import from, or handling or storage of such goods in connection with such transport
5. Exhibition or convention services;
6. Training or retraining for any business or employment;
7. Services supplementary to, including the organising services referred to in sub-paragraphs (e) and (f).
8. This list of prescribed services above cannot include any services related to accommodation and entertainment.

The prescribed services must be supplied:

• under a contract with a person belonging to an overseas country in his business capacity; and
• which directly benefit a person belonging to an overseas country in his business capacity.

For services (a) and (b) stated in the prescribed list, the services must not relate directly to any land or goods situated in Singapore, other than goods for export.

For services (a) to (d) stated in the prescribed list that make reference to goods for export, the requirement for definite and immediate intention for export under S21(3)(g) similarly applies.

Unlike S21(3)(j) above, your overseas customer can be in Singapore to receive these services.

S21(3)(k)

Example for (a) and (b):

You provide consultancy services on 'feasibility of conducting business in Singapore' to your overseas customer.
Example for (d):

If you supply transport and handling services to an overseas customer from the point of import (e.g. Free Trade Zone) to the warehouse that the goods were consigned, your transport and handling services can be zero-rated.

GST Guide for the Logistics Service Industry (536KB)

Example for (f) and (g):

You provide training (excluding formal education courses such as diploma, graduate and post-graduates courses) in Singapore for participants from all over the world (including Singapore). You may zero-rate your training fees to overseas companies who send their overseas staff to attend the course in Singapore.

14

Certain services in connection with:

1. the handling of ships or aircraft, or
2. the handling or storage of goods carried in the ship and aircraft.

The services are prescribed in the Third Schedule of GST (International Services) Order. 

Please refer to paragraph (l) in the  extract of Section 21 of the GST Act (207KB).

S21(3)(l)

Example for item no. 14: You provide handling and storage services within FTZs or designated areas for imported goods or goods to be exported. 

GST Guide for the Aerospace Industry

(928KB)

GST Guide for Logistics Service Industry

(536KB) -

relevant only for item no. 14

15

Pilotage, salvage or towage services

S21(3)(m)

16

Services comprising the surveying or classification of any ship and aircraft for the purposes of any register

S21(3)(n)

17

Supply (including the letting and hire) of any ship or aircraft

The ship or aircraft is not leased for the purpose of providing the following services substantially in Singapore:

1. transport of passengers,
2. accommodation,
3. entertainment,
4. catering of food or beverages, or
5. education services

S21(3)(o)

18

Certain services comprising the repair, maintenance, broking or management of any ship or aircraft

The services are prescribed in the Sixth Schedule of GST (International Services) Order. Please refer to paragraph (p) in the  extract of Section 21 of the GST Act (207KB).

S21(3)(p)

19

Supply (including the letting or hire) of qualifying aircraft parts

Aircraft parts must be parts and equipment designed and built for exclusive use on an aircraft.
They should be certified as airworthy by:

1. a person certificated by a national civil aviation authority (for non-military aircraft); or
2. the government owning that aircraft (for military aircraft)

S21(3)(x)

20

Certain services in connection with the provision of an electronic system relating to import and export of goods.

The services are prescribed in the Seventh Schedule of GST (International Services) Order. Please refer to paragraph (t) in the extract of Section 21 of the GST Act (207KB).

S21(3)(t)

You provide an electronic system through which the application of import/ export permits can be made. You may zero-rate the processing fee charged to customers who use your permit application system.

21

The qualifying services are:

1. storage services;
2. goods management services;
3. services of holding an auction or exhibition of the goods;
4. broking services and other similar services;
5. conservation and restoration services;
6. valuation services; and
7. insurance services.

It includes services performed on goods during the period in which the goods are temporarily removed from a warehouse under the SWS (for repair, maintenance or for an auction, exhibition or other similar event), and returned to any warehouse under SWS after the event.

The qualifying services must be supplied:

1. under a contract with an overseas person ; and
2. which directly benefit an overseas person .

The services must be performed on qualifying goods stored in a warehouse under the Specialised Warehouse Scheme (SWS) :

1. a work of art;
2. an antique;
3. an artefact;
4. a collector's item;
5. a precious metal (gold, silver, platinum, palladium);
6. a precious stone (diamond, ruby, sapphire, emerald);
7. jewellery; or
8. wine

according to the Ninth Schedule of the GST (International Services) Order.

For more information, refer to paragraph (y) in the extract of Section 21 of the GST Act (207KB).

S21(3)(y)

Specialised Warehouse Scheme and Zero-rating of Supplies (368KB)

The e-Tax guide also contains information on the zero-rating of a supply of storage space in a warehouse under SWS (e.g. the provision of 'private storage units'). This is regarded as a supply of goods, instead of storage services, for GST purposes.

22

Sale and lease of air and sea containers

The containers:

1. are used or to be used for international transportation of goods; and
2. comply with the prescribed requirements in the Eight Schedule of GST (International Services) Order.

Please refer to paragraph (v) in the extract of Section 21 of the GST Act (207KB).

S21(3)(v)

GST: Zero-rating of Sale & Lease of Containers and Container Services (110KB)

23

Certain services comprising the repair, maintenance or management of any air or sea containers.

The containers:

1. are used or to be used for international transportation of goods; and
2. comply with the prescribed requirements in the Eight Schedule of GST (International Services) Order.

Please refer to paragraph (w) in the extract of Section 21 of the GST Act (207KB).

S21(3)(w)

24

Certain services comprising the provision of telecommunications.

The services are prescribed in the Fifth Schedule of GST (International Services) Order. Please refer to paragraph (q) in the extract of Section 21 of the GST Act (207KB).

Services must comprise telecommunications transmitted:

1. into and out of Singapore; or
2. outside Singapore.

S21(3)(q)

You are a telecommunications company and provide auto roaming service and international calls.
Zero-rating Telecommunication and Related Services under Section 21(3)(q) (202KB)

25

Trust services in relation to a foreign trust

1. a trustee of the foreign trust (including a trust company providing services in its capacity as trustee of the foreign trust); or
2. a trust company to a trustee of the foreign trust

S21(3)(r)