Withholding Tax Rates

A payer must withhold tax when certain types of payments (e.g. interest, royalty, services etc) are made to non-resident companies. Find out more on payer's filing obligations and calculation of withholding tax payable using the Withholding Tax Calculator.

Withholding Tax Rates for Services, Interest, Royalty, Rent of Moveable Properties, etc.

Nature of IncomeTax 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 moveable 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 moveable properties

15% 1

Technical assistance and service fees

Prevailing Corporate Tax rate3 5

Management fees

Prevailing Corporate Tax rate3 5

Time, voyage and bareboat charter fees for the charter of ships

NIL

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

Withholding Tax Rates for Aircraft Charter

Time Charter Fees and Voyage Charter Fees for the Charter of AircraftsTax Rate

(a) Paid to a resident of a tax treaty partner 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%1, whichever is the lower amount

(b) Paid to a resident of a tax treaty partner who is not an aircraft operator (i.e. the "Shipping and Air Transport" Article of the treaty does not apply)

 2%1

(c) Paid to a resident of a jurisdiction which has no tax treaty with Singapore

 2%1

Bareboat Charter Fees for the Charter of Aircraft

Tax Rate

(a) Paid to a resident of a tax treaty partner 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%1 whichever is the lower amount

(b) Paid to a resident of a tax treaty partner 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%1(unless it is further reduced by other provision of the tax treaty such as the "Royalty" Article)

(c) Paid to a resident of a jurisdiction which has no tax treaty with Singapore

2%1

1These withholding tax rates apply when the income is derived by the non-resident person through operations carried on outside Singapore. They are to be applied on the gross payment. The resulting tax payable is a final tax. The following tax rates apply on gross payments when operations are carried out in Singapore:

2The reduced withholding tax rate of 10% applies to payments due and payable on or after 1 Jan 2005.

3Withholding tax is based on the prevailing corporate tax rate for the year when the services were provided, even if payment to the non-resident is made in a different year. For example, if the service was provided in Dec 2008 but payment was made in 2009, the prevailing corporate tax is that for 2008(Year of Assessment 2009), which is 18%.
For payments made to non-resident individuals, tax is to be withheld at 20% (from 1 Jan 2016, the rate will be increased to 22%) 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 2020 [Section 43(3B) of the Income Tax Act]. From 16 Feb 2007, withholding tax does not apply to any distribution made by the trustee of the REIT where tax has already been paid, on the income from which the distribution is made, by the trustee of the trust [Section 45G(4) of the Income Tax Act].


If 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. The beneficiaries^ may be any of the following:

  • 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);
  • trade union registered under the Trade Unions Act (Cap. 333); or
  • an international organisation that is exempt from tax on such distributions by reason of an order made under the International Organisations (Immunities and Privileges) Act (Cap. 145) [Section 45G(4B) of the Income Tax Act].

^ Do not include a person acting in the capacity of a trustee.
The trustee,in turn will refund the amount to the nominees who will then refund it to the beneficiaries. For this purpose, the trustee is required to send its request for refund with all the original subsidiary income tax certificates on a consolidated basis. Please send your request to:


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

5 Tax Refund under S46 of ITA for payments withheld at prevailing corporate tax rate.

Where the recipient of the income is resident in a jurisdiction which has an Avoidance of Double Taxation Agreement (DTA) with Singapore, the rates specified in the DTA 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.

You may download the template, Specimen Format of Certificate of Residence (COR) from Non-Resident (44KB) for your use and reference.

The COR from Non-Resident that we provided is a specimen format and not a prescribed form or template. 

 

Tax Refund under S46 of ITA for Payments Withheld at Corporate Tax Rate

If withholding tax is imposed at the prevailing corporate tax rate on the gross payment, the tax is not the final tax. If the non-resident company wishes to claim for the expenses incurred in deriving the income, it may forward the certified accounts and tax computation for IRAS' examination.

Please include the following information with your tax computation:

  1. Full name of payer
  2. Tax reference number of the payer
  3. Nature of payment
  4. Date of payment to non-resident
  5. Period the payment covers
  6. Gross amount of payment
  7. Amount of tax deducted and accounted to IRAS

When the net income and tax have been determined, any tax withheld in excess of the tax on the net income will be refunded.

If the company is a resident of a tax treaty jurisdiction, the Avoidance of Double Taxation Agreement (DTA) may provide for relief from double taxation, depending on the provisions of the DTA.

 

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