Singapore

Corporate taxation

The corporate income tax rate is 17%. There is a 50% corporate income tax rebate, capped at SGD 25,000. There is also a partial tax exemption of 75% on the first SGD 10,000 and 50% on the next SGD 290,000 of the company’s income subject to tax at prevailing corporate tax rate. Qualified start-up companies may be granted an exemption on the first SGD 100,000 of normal chargeable income, and a further 50% exemption on the next SGD200,000, for its first three consecutive years of assessment.

Corporate tax incentives

Singapore offers various special regimes, subject to differentiated tax rates, including related to leasing, finance and treasury, insurance and shipping among others.

Singapore is a Secrecy and Low Tax Jurisdiction and functions as the financial center for “offshore” funds of Asian companies (much like Switzerland for US and European companies). There are Strict legislation on banking confidentiality. Singapore is also used as a hub for MNE regional subsidiaries.

There are no withholding taxes.

Transfer pricing

Reference to TPG is provided under section 34D of the Singapore Income Tax Act. Singapore provides guidance on determining the arm’s length price (i.e. transfer pricing methods, comparability adjustments, etc.) in the Singapore Transfer Pricing Guidelines which are outside the transfer pricing legislation. The Singapore Transfer Pricing Guidelines followed largely the key principles laid down in the OECD Transfer Pricing Guidelines. The Guidelines also mentioned that Singapore takes guidance from the OECD Transfer Pricing Guidelines, including the guidance in the Actions 8-10: 2015 Final Reports on Aligning Transfer Pricing Outcomes with Value Creation. (See section 4 of Singapore Transfer Pricing Guidelines.). In addition, the Singapore Transfer Pricing Guidelines laid down expectations and practices that are specifically relevant to the Singapore taxpayers.

Links

Transfer Pricing Case Law

Case NameDescriptionDateCountryKeywords

Cases involving Singapore

Case NameDescriptionDateKeywords