What is a Certificate of Residence (COR)
A COR is a letter certifying that a company is a tax resident in Singapore, i.e. controlled and managed in Singapore.
Why Apply for a COR
Companies need this certificate to claim tax benefits under the DTAs that Singapore concluded with foreign jurisdictions. Jurisdictions that conclude DTAs with Singapore are referred to as "treaty partners".
Income derived by a Singapore tax resident company from foreign persons or companies may be subject to tax in that foreign jurisdiction. Under DTAs, treaty partners may provide tax breaks (e.g. tax exemptions and lower withholding tax rates) to tax residents of Singapore on income derived from their jurisdictions. Non-residents do not enjoy these benefits.
The COR is required by and must be submitted to the foreign tax authority of the treaty partner to prove that the company is a Singapore tax resident.
ABC Pte Ltd is a Singapore tax resident company. It received royalty income from Company XYZ who is a tax resident of Australia and would be subject to withholding tax at 30%. Under the Singapore-Australia DTA, the withholding tax for royalty is reduced from 30% to 10%. ABC Pte Ltd needs to produce the COR to the Australia tax authority to enjoy the lower withholding tax rate of 10%.
Some treaty partners require the Singapore tax resident company to complete and submit a tax reclaim form issued by the treaty partner. For more information on the tax reclaim form, please refer to Tax Reclaim Form.
If you are not claiming benefits under the DTA but wish to obtain a letter certifying that the company is a tax resident in Singapore, you may write to IRAS on the company's letterhead with the following information:
- Name and Unique Entity Number (UEN) of the company;
- Reason(s) for requesting the letter of residence;
- Confirmation that the control and management of the company is exercised in Singapore; and
- Year of Assessment for which the letter is required.
Companies Eligible to Apply for COR
To apply for or obtain a COR, companies must:
- be tax residents in Singapore; and
- the foreign income is remitted or going to be remitted into Singapore.
Nominee companies are not eligible to apply for COR as they are not the beneficial owner of the income derived from the foreign treaty partner. A nominee company is a company that acts as custodian of shares on behalf of the beneficial owners.
Foreign-owned investment-holding companies with purely passive sources of income receive only foreign-sourced income are not eligible to apply for COR. A foreign-owned company is a company where 50% or more of its shares are held by foreign companies/shareholders.
However, IRAS may still issue a COR if these companies are able to satisfy IRAS that:
- The control and management of the company is in Singapore; and
- The company has valid reasons for setting up an office in Singapore.
To satisfy IRAS of the conditions listed above, such companies must demonstrate that decisions on strategic matters are made in Singapore, for example by showing IRAS that their Board of Directors' meetings are held in Singapore. Besides this, the company must also:
- Have related companies in Singapore that are tax residents or that have business activities in Singapore; or
- Receive support or administrative services from a related company in Singapore; or
- Have at least 1 director based in Singapore who holds an executive position and is not a nominee director; or
- Have at least one key employee (e.g. CEO, CFO, COO) based in Singapore.
Non-Singapore incorporated companies and Singapore branches of foreign companies are not eligible to apply for COR, except for the exceptional scenarios stated below, as these companies are not controlled or managed in Singapore. For Singapore branches of foreign companies, they are controlled and managed by their overseas parent company.
However, IRAS may still issue a COR if these companies are able to satisfy IRAS that:
- The control and management of the company is in Singapore (i.e. the Singapore branch is exercising the full control and management of the company); and
- The company has valid reasons for not incorporating in Singapore.
IRAS reserves the right to request for additional information on the company.
How to Apply for COR
New! In line with Government’s direction to harness technology for enhanced productivity, all COR applications have to be e-Filed via
myTax Portal from 1 Jun 2017. Paper applications will no longer be accepted from this date onwards.
Online via myTax Portal
Log in to
mytax.iras.gov.sg to apply.
You can apply for COR online for:
- the current Year of Assessment (YA);
- the next YA; or
- up to two previous YAs.
For example, in the year 2017, the company may apply COR for YA 2017, YA 2018, and YAs 2015 to 2016.
Company staff or tax agents must first be authorised for 'Corporate Tax Matters' via the
e-Services Authorisation System (EASY) to log in and apply for COR on behalf of the company.
IRAS will process your application within 7 working days of receiving the application and mail the COR to the company's registered address. Please allow up to 4 working days to receive it in your mail.
Once your application is processed (within 7 working days), a duplicate copy of the approved COR will be made available in
mytax.iras.gov.sg. You will also have the option to print or download the approved COR.
Getting help on online application for COR
- Get instant guidance by accessing our user guides and frequently asked questions.
- Contact us
You may contact us to obtain assistance:
- Easy Access Code/ myTax Portal (Log-in enquiries) - 1800 356 8015
- COR matters for companies - 1800 356 8622
This is applicable to companies that:
- wish to apply for COR for a YA that is more than two years prior to the current YA; or
- are non-Singapore incorporated companies.
Download, fill out and send the form
Application for Certificate of Residence (946KB) to IRAS. Please ensure that the form is duly completed and signed. IRAS will process your application within 14 working days from the day we receive the duly completed and signed application form. All COR will be mailed to the company's registered address. Please allow up to 4 working days to receive it in your mail.
Once your application is processed (within 14 working days), a duplicate copy of the approved COR will be made available in
mytax.iras.gov.sg. You will also have the option to print or download the approved COR. To find out how to view the COR via
mytax.iras.gov.sg, please refer to our
user guide (534KB).
What is a Tax Reclaim Form
A Singapore tax resident company applying for treaty benefits under the DTA from a tax treaty partner may be required to complete and submit a tax reclaim form issued by the tax treaty partner.
The tax reclaim form may require certification by IRAS, as a Singapore Competent Authority, that certain conditions such as Singapore tax residency status is met before it can be submitted to the foreign tax authority for claiming treaty benefits.
Certification of Tax Reclaim Form by IRAS
After completing the tax reclaim form, please forward the original signed form (i.e. not the photocopy) to IRAS at the following address:
Inland Revenue Authority of Singapore
55 Newton Road
Important Points to note:
Companies forwarding the tax reclaim form for IRAS' certification must ensure that the tax reclaim form is properly completed and duly signed. If the tax reclaim form is incomplete, IRAS will not be able to certify it and the company is required to re-submit a properly completed form. Examples of incomplete forms are:
- those that are not signed by authorised persons;
- forms with missing information and
- back-dated or posted-dated forms. The date indicated on the tax reclaim form should be the current date.
In addition, photocopies / faxed copies of the form are not acceptable as IRAS can only certify on the original form.
When You Will Receive The Certified Tax Reclaim Form
IRAS strives to process the tax reclaim forms within one month from the date of receiving the duly completed and signed forms. In most cases, IRAS processes the tax reclaim forms within two weeks of receiving the duly completed and signed forms.
We will post the tax reclaim form to the company's registered address upon certification. If you wish to collect the tax reclaim form by hand, please indicate in a covering letter that accompanies the tax reclaim form that you wish to collect the certified form by hand and provide your contact details.
Who Can Collect The Tax Reclaim Form
Collection of the tax reclaim form is strictly by appointment only. We will contact you to make an appointment for collection once the form is certified.
Persons who can collect the certified tax reclaim form on behalf of the company are:
- Director of the company. He is required to produce his NRIC for verification; or
- Authorised person of the company. He is required to produce his NRIC and an original authorisation letter (using company's letterhead) stating his full name, NRIC number and the document that he wishes to collect. Scanned or photocopied authorisation letters will not be accepted.
Please proceed to the Taxpayer Services Centre, 1st storey, Revenue House for the collection.
Indonesia's Tax Reclaim Form (Form - DGT 1)
Please note that IRAS will only endorse one copy of Indonesian Tax Reclaim Form (Form - DGT 1) for each Indonesia Withholding Agent within a 12-month period. According to Indonesia's guidelines, each Form - DGT 1 is valid for a period of 12 months from the endorsement date. As such, if there are subsequent transactions with the same Indonesia Withholding Agent within the 12-month period, the Singapore tax resident does not need to obtain another endorsement from IRAS. The Singapore tax resident will only need to furnish Page 2 of the Form to the Indonesian Tax Authority.
The endorsed Form - DGT 1 will be valid for a period of 12 months from the endorsement date if the two conditions below are met:
- The income is paid by the same Indonesian Withholding Agent; and
- The name and address of the income recipient are not changed.
Subsequent Renewal (By Post):
If there are transactions with the same Indonesia Withholding Agent after the 12 month period, please submit a new Form - DGT 1 by post. You are encouraged to post the Form - DGT 1 to IRAS one month before the expiry of the Form.