To claim tax benefits under an Avoidance of Double Tax Agreement (DTA) or a Limited Treaty, Singapore tax resident companies can apply for a Certificate of Residence or seek IRAS’ certification of a tax reclaim form.

Certificate of Residence

What is a Certificate of Residence

The Certificate of Residence (COR) is a letter issued by IRAS to certify that the company is a tax resident of Singapore (i.e. the control and management of its business is exercised in Singapore) for the purpose of claiming tax benefits under the DTAs or Limited Treaties.

Generally, income derived by a Singapore tax resident company from foreign persons or companies may be subject to tax in that foreign jurisdiction.

Under the DTAs or Limited Treaties that Singapore has concluded with foreign jurisdictions (i.e. DTA partners), Singapore tax residents may enjoy tax benefits (e.g. tax exemptions or lower withholding tax rates) on income derived from the foreign jurisdictions. Non-residents do not enjoy these benefits.

To enjoy such tax benefits, the COR is required by and must be submitted to the tax authority of the DTA partners to prove that the company is a Singapore tax resident.

For information

For DTAs with Limitation of Relief provisions, the Singapore tax resident company must meet an additional condition to claim DTA benefits (i.e. it must remit or will remit to Singapore the foreign-sourced income that is taxable in Singapore on a remittance basis).

Example

ABC Pte Ltd is a Singapore tax resident company. It received royalty income from Company XYZ, who is a tax resident of Australia, and is subject to withholding tax at 30% in Australia.

However, if ABC Pte Ltd submits the COR to the Australia tax authority, it can enjoy a lower withholding tax rate of 10% on the royalty income under the Singapore-Australia DTA.

If you are not claiming benefits under the DTA but wish to obtain a letter certifying that the company is a tax resident of Singapore, you may write to IRAS using the company's letterhead with the following information:

  • Name and Unique Entity Number (UEN) of your company
  • Reason(s) for requesting for a letter of residence
  • Confirmation that the control and management of the company is exercised in Singapore
  • Calendar year for which the letter is required

Who is Eligible for a Certificate of Residence

To obtain a Certificate of Residence (COR), a company must be a tax resident of Singapore. Generally, foreign-owned investment holding companies, nominee companies and non-Singapore incorporated companies are not eligible for a COR.

Foreign-Owned Investment Holding Companies

Foreign-owned investment holding companies with purely passive sources of income and receiving only foreign-sourced income are not eligible for a COR. A foreign-owned company is a company where 50% or more of its shares are held by:

  • Foreign companies that are incorporated outside Singapore; or
  • Individual shareholders who are not citizens of Singapore.

The ownership is applied at the ultimate holding company level.

However, IRAS may still issue a COR if these companies can show that:

  • The control and management of the company's business is exercised in Singapore; and
  • The company has valid reasons for setting up an office in Singapore.

This includes demonstrating that decisions on strategic matters are made in Singapore (e.g. by showing IRAS that their Board of Directors' meetings are held in Singapore). The company must also:

  • Have related companies in Singapore that are tax residents of Singapore or have business activities in Singapore;
  • Receive support or administrative services from a related company in Singapore;
  • Have at least 1 director based in Singapore who holds an executive position and is not a nominee director; or
  • Have at least 1 key employee (e.g. CEO, CFO, COO) based in Singapore.

Nominee Companies

Nominee companies are not eligible for a COR as they are not the beneficial owner of the income derived from the DTA partner. A nominee company is a company that acts as a custodian of shares on behalf of the beneficial owners.

Non-Singapore Incorporated Companies

Non-Singapore incorporated companies are not eligible for a COR as these companies are not controlled or managed in Singapore. This also applies to Singapore branches of foreign companies, as they are controlled and managed by their overseas parent company.

However, in exceptional situations, IRAS may still issue a COR if these companies can show that:

  • The control and management of the company's business is exercised 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 may request for additional information on the company.

Variable Capital Companies (VCC)

For tax purposes, a VCC incorporated under the Variable Capital Companies Act is treated as a company.

To obtain a COR, a VCC must be a tax resident of Singapore. The tax residence of a VCC’s sub-funds is determined at the umbrella level of the VCC. To obtain a COR for its sub-fund, the VCC, and not the sub-fund, has to apply for the COR. The COR will show the details (tax reference number and name) of the VCC and sub-fund.

How to Apply for a Certificate of Residence

All Certificate of Residence (COR) applications have to be filed via mytax.iras.gov.sg, except for specific circumstances.

You can apply for a COR via mytax.iras.gov.sg for:

  • The current calendar year
  • Up to 4 back calendar years

For example, in the calendar year 2021, the company may apply for a COR for the calendar years 2017 to 2021.

The company may also apply for a COR for 1 advance calendar year starting from Oct of the current calendar year.

The COR is granted to the company for the calendar year only if the control and management of its business is exercised in Singapore in the specified calendar year. If the COR is granted for the calendar year 2021, it means that the company is a tax resident of Singapore throughout the calendar year 2021.

For assistance on applying for a COR, refer to these guides:

Processing Time

IRAS will process your application within 7 working days of receiving the application.

Once your application is processed, a digital copy of the approved COR will be made available at the View Notices/ Letters - Corporate Tax digital service at mytax.iras.gov.sg. You may print or download the approved COR.

If your company’s notice preference in the Update Notice Preferences digital service is email notifications, you will receive the email notification within 1-3 working days that the digital COR is available at mytax.iras.gov.sg. No paper notice will be sent if your company is on email notifications.

If your company’s notice preference in the Update Notice Preferences digital service is paper notices, you will receive the paper COR at your company’s registered address within 4 working days. 

Learn how to update your company’s notice preference.

Specific Circumstances to Apply for a COR in Writing

This is only applicable to companies that are:

  • Applying for a COR for a sole-proprietorship business owned by the company
  • Applying for a COR for a partnership business of which the company is a partner
  • Non-Singapore incorporated

These companies may write to IRAS via myTax Mail with the following details:

  • Name and Unique Entity Number (UEN) of the company/ sole-proprietorship/ partnership
  • Reason(s) for requesting for the COR
  • Calendar year for which the COR is required
  • Name of DTA country/ territory
  • Nature and amount of income to be derived from DTA country/ territory
  • Name of the foreign company/ person paying the income
  • Date of remittance of income
  • Confirmation that the control and management of the business of the company for the whole of the calendar year is/ will be exercised in Singapore

IRAS will process your application within 14 working days from the day complete information is received. The processing time may be longer if the case is complex.

Once your application is processed, a digital copy of the approved COR will be made available at the View Notices/ Letters - Corporate Tax digital service at mytax.iras.gov.sg. You may print or download the approved COR.

If your company’s notice preference in the Update Notice Preferences digital service is email notifications, you will receive the email notification within 1-3 working days that the digital COR is available at mytax.iras.gov.sg. No paper notice will be sent if your company is on email notifications.

If your company’s notice preference in the Update Notice Preferences digital service is paper notices, you will receive the paper COR at your company’s registered address within 4 working days. 

Learn how to update your company’s notice preference.

FAQs

  1. Can my company request for duplicate certificates?

    You can print a copy of your Certificate of Residence (COR) from mytax.iras.gov.sg without incurring a fee. You do not need to submit another application for the COR. Learn how to view the COR (PDF, 198KB) via mytax.iras.gov.sg.

    If you wish to obtain a hardcopy duplicate of the COR from IRAS, you may request for a hardcopy duplicate to be mailed to you at a fee. Find out more about the procedure to obtain a hardcopy duplicate of the COR.

Tax Reclaim Form

What is a Tax Reclaim Form

A Singapore tax resident company applying for DTA benefits under the DTA with a DTA partner may be required to complete and submit a tax reclaim form issued by the DTA partner with or in place of a Certificate of Residence (COR).

The tax reclaim form may require IRAS’ certification that certain conditions, such as Singapore tax residency status, are met before it can be submitted to the foreign tax authority for claiming DTA benefits.

How to Obtain IRAS’ Certification of Tax Reclaim Form

After completing the tax reclaim form, forward the original signed form (i.e. not a photocopy) to IRAS at the following address:

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

Companies forwarding the tax reclaim form for IRAS' certification must ensure that the tax reclaim form is duly completed and signed. 

IRAS cannot certify incomplete forms. Examples of incomplete forms include:

  • Forms not signed by authorised persons
  • Forms with missing information
  • Back-dated or post-dated forms. The date indicated on the tax reclaim form should be the current date

Companies who submit incomplete forms have to re-submit duly completed forms if they wish to obtain IRAS’ certification.

IRAS will process the tax reclaim form within 1 month of receiving the duly completed and signed form. In most cases, IRAS processes the tax reclaim form within 2 weeks of receiving the duly completed and signed form. 

The certified tax reclaim form and a cover letter will be mailed to the company’s registered address after the application is processed. A duplicate copy of the cover letter will be made available at the View Notices/ Letters - Corporate Tax digital service at mytax.iras.gov.sg.

FAQs

  1. Are there any charges imposed for the certification?

    No, the certification is free of charge.

  2. Can I submit Indonesia’s tax reclaim forms (DGT Form 1 and DGT Form 2) for IRAS’ certification?

    IRAS’ certification is not required on the DGT Forms. Companies only need to submit a Certificate of Residence (COR) together with a completed DGT Form to the Indonesia Tax Authority to claim DTA benefits under the Singapore-Indonesia DTA.

    The DGT Forms are valid for the calendar year as stated in the COR. For example, if the COR certifies that a company is a Singapore tax resident for the calendar year 2021, the DGT Form is valid for all payments received or receivable from Indonesia in the calendar year 2021 (i.e. from Jan 2021 to Dec 2021).

    If the payment period or income straddles 2 calendar years, companies can apply for 2 CORs for the relevant calendar years. For example, a company may apply for a COR each for the calendar years 2020 and 2021 to cover a service contract that lasts from Jul 2020 to Jun 2021.