Investment in SingaporeAn overview of regulatory and tax laws

14 - 15 November 2006New Delhi

byDavid K.K. Chong

M.Sc., LL.M.,Advocate & Solicitor of Singapore

Advocate & Solicitor of MalayaAdvocate & Solicitor of BruneiBarrister of England & Wales

Solicitor of AustraliaBarrister & Solicitor of British Virgin Islands

Why Singapore?

Swiss-based

most competitive economy in the world

Washington-based

most free economy in the world

magazine

world’s best city for businessbest city in Asia to work and live in

World Economic Forum

Heritage Foundation

Fortune

Legal Framework & Justice

Swiss-based

ranked legal framework 1st

in terms of level of confidenceinternational business community hasin the administration of justiceranked 4th

‘World Competitiveness Yearbooks’

International Institute of Management Development

Justice

1. Denmark

2. Norway

3. Canada

4. Singapore

5. New Zealand

6. Australia

7. Switzerland

8. Hong Kong

9. Ireland

10. Finland

11. Iceland

12. Netherlands

13. Austria

14. Israel

15. Sweden

16. United Kingdom

17. Germany

18. Luxembourg

19. USA

20. Malaysia

Legal System

Singapore law is based on English law

Singapore tax & company law also based on English principles

once upon a timeSection 5 Civil Law Actprovided for the law of Englandto be observed in all commercial matters

Income subject to Tax

Section 10(1) ITA

(a) profits from any trade, business, profession or vocation

(b) profits from any employment

(d) dividends, interest or discounts

(e) pension, charge or annuity

(f) rents, royalties, premiums

(g) any gains or profits of an income nature

not falling within any of above

Capital Gains

Capital Gains not subject to tax

except:

Section 10F ITAgains from short-term real property transactionson or after 15 May 1996before the expiration of 3 years from date of acquisition

Section 10G ITAgains from short-term transactions of sharesin private real property companies

Approved Holding Companies

Approved Holding Companies

Any gain by AHCon the disposal of shares in subsidiarieswill be treated as a capital gain if:

immediately prior to date of disposal of shares; and from date company is granted AHC status

to date of disposal of shares

they own at least 50% of the sharesfor a period of not < 18 months continuously

AHC status granted from 17 February 2006 to 16 February 2011

Tax certainty for 5 years from date of AHC status

Loss from sale of shares cannot be set off against other income

Simple System

no CFC rules

no thin capitalization rules

no capital duty

no transfer pricing rulesexcept section 53(2A) ITA& guidelines in IRAS Circular 23 February 2006‘IRAS endorses the arm’s length principleas the standard to guide transfer pricing.The arm’s length principle is the internationally accepted standardadopted by many member countries of the OECD….’

Transfer Pricing (1)

Section 53(2A) ITA

where a non-resident person carries on business with a resident personand it appears to the Comptrollerthat owing to the close connection between the resident person and the non-resident personand to the substantial control exercised by the non-resident person over the resident personthe course of business between those personscan be so arranged and is so arrangedthat the business done by the resident personin pursuance of his connection with the non-resident personproduces to the resident personeither no profits or less than the ordinary profitswhich might be expected to arise from that businessthe non-resident person shall be assessable and chargeable to taxin the name of the resident personas if the resident person were an agent of the non-resident person.

Transfer Pricing (2)

Section 53(3) ITA

true amount of profitscannot be readily ascertainedComptroller assess and chargefair and reasonable percentage of the turnover of the business

cost plus 5%

onshore

offshore

20%

10%

0%

not remitted

capital

income

0%

0%

remitted

13(8) ITA

13(9) ITA0%

3 types of DT relief

9.5%

Taxation of Singapore Companies

Singapore Tax System

Singapore’s tax system isterritorial and remittance based

Section 10(1) ITA

income tax shall be payable on the income‘accruing in or derived from Singapore [territorial]or received in Singapore from outside Singapore [remittance]’.

Individual Tax Rate

YA 2006

chargeable income SGD rate

for every $ of the 1st 20,000 Nil

for every $ of the next 10,000 3.75%

for every $ of the next 10,000 5.75%

for every $ of the next 40,000 8.75%

for every $ of the next 80,000 14.5%

for every $ of the next 160,000 18%

for every $ exceeding 320,000 21%

Remittance of Foreign-Sourced Income(Individual)

Section 13(7A) ITA

There shall be exempt from taxany income arising from sourcesoutside Singaporeand received in Singapore:

(a) by any individualwho is not resident in Singapore; and

(b) on or after 1st January 2004by any individual who is resident in Singaporeif the Comptroller is satisfied thatthe tax exemption would be beneficial to the

individualbut excludes such income received by himthrough a partnership in Singapore

Company Tax Rate

20%

cf. Hong Kong 17.5%

Economic Expansion Incentives(Relief from Income Tax) Act Cap. 86

concessionary rate of tax 10%e.g. Section 43E ITA headquarters company (‘OHQ’)

Tax Exemption Scheme for New Companies

1st SGD 100,000 chargeable income(excluding Singapore dividends)

full tax exemption will apply to1st 3 consecutive Years of Assessmentfalling within YA 2005 to YA 2009

conditions: incorporated in Singapore tax resident of Singapore not > 20 shareholders all shareholders are individuals

Partial Exemption

20%

1st SGD 10,000 75% exempt(SGD 2,500 x 20% = 500)

next SGD 90,000 50% exempt(SGD 45,000 x 20% = 9,000)

500 + 9,000 = 9,500

therefore 1st SGD 100,000 taxed at effective rate of 9.5%

onshore

offshore

20%

10%

0%

not remitted

capital

income

0%

0%

9.5%

Remittance of Foreign-Sourced Income(Company)

Section 13(8) ITAtax exemptionreceived in Singapore on or after 1 June 2003(need not be earned on or after 1 June 2003)

foreign-sourced dividend(no shareholding requirement)

foreign branch profits foreign-sourced service income

Section 13(9) ITA2 conditions:

foreign-sourced income subjected to tax in foreign jurisdiction

headline tax rate of foreign jurisdiction 15%

IRAS Circulars (1)

IRAS CircularsTax Exemption for Foreign-sourced Dividend,Foreign Branch Profits andForeign-sourced Service Income

IRAS Main Circular 21 May 2003

IRAS Supplementary Circular 30 July 2004

IRAS Supplementary Circular 31 May 2006

IRAS Circulars (2)

Singapore Co. Singapore Co.

Hong Kong Co. Mauritius Co.

Investments Investments

onshore

offshore

20%

10%

0%

not remitted

capital

income

0%

0%

remitted

13(8) ITA13(9) ITA

0%

9.5%

Relief against Double Taxation

3 types of relief against double taxation: Section 48 ITA Commonwealth income tax relief Section 50 ITA DTAs Section 50A ITA no DTAs

Section 49 ITA double tax arrangements

Section 50 ITA tax credits not all DTAs provide tax relief for underlying tax

Section 50A ITA unilateral tax credits tax relief for underlying tax if 25% 25% apply to Minister of Finance for waiver

unilateral tax credits: income from certain professional services

rendered in certain ‘non-treaty’ countries employment income dividends profits from overseas branch

of Singapore resident company qualifying royalty income

Commonwealth Income Tax Relief (1)

Section 48(1) ITA resident

lower of: Commonwealth rate of tax half Singapore rate of tax

Section 48(2) ITA non-resident

(a) if Commonwealth rate does not exceed Singapore rate

half Commonwealth rate of tax

(b) if Commonwealth rate exceeds Singapore ratethe difference between:

the Singapore rate of tax half Commonwealth rate of tax

Commonwealth Income Tax Relief (2)

Commonwealth countries no DTA with Singapore:

1. Bahamas 10. Nauru2. Botswana 11. Nigeria3. Brunei 12. Samoa4. Gambia 13. Sierra Leone5. Ghana 14. Swaziland6. Guyana 15. Tanzania7. Kenya 16. Tonga8. Lesotho 17. Uganda9. Malawi 18. Zambia

Unilateral Tax Creditsfor Dividend Withholding Tax

Section 50A(1)(c)

notwithstanding that there are no arrangements under Section 49with the government of any territory outside Singapore,tax credit under Section 50 shall… be givento any person resident in Singaporefor tax payable under the law of that territoryin respect of any dividend derived therefrom

Section 50A(2) ITA

where any dividend in respect of which tax credit is givenunder Section 50A(1)(c) ITAis paid by a company which is resident outside Singaporeto a person resident in Singaporewho owns not less than 25%of the shares of the company paying the dividendthe tax credit shall take into accountany tax paid by that companyin the country in which it is residentin respect of its incomeout of which the dividend is paid

Unilateral Tax Creditfor Underlying Corporate Tax (1)

Unilateral Tax Creditfor Underlying Corporate Tax (2)

Section 50A(3) ITA

where under arrangements under Section 49with the government of any territory outside Singaporeno provision is made for tax credit in respect of incomeout of which any dividend is paidby a company resident in that territory,tax credit under Section 50 in respect of such incomeshall be given to any person resident in Singaporewho owns not less than 25%of the shares of the company paying the dividend

Section 50A(6)

Minister may waive requirement of25% share ownershipunder Section 50A(2) & (3)

DWHT & Underlying Corporate Tax

Singapore Co. 0%

USA Co.

35% corporate tax

30% DWHTnot < 25% shareholding

onshore

offshore

20%

10%

0%

not remitted

capital

income

0%

0%

remitted

13(8) ITA

13(9) ITA0%

3 types of DT relief

9.5%

Taxation of Singapore Companies

One-Tier Corporate Tax System

wef 1 January 2003

one-tier corporate tax systemreplaced old imputation system

CBDT Circular 789 13 April 2000

Central Board of Direct Taxes (CBDT)Department of RevenueMinistry of FinanceCircular 789 of 13 April 2000

Certificate of Residence issued by Mauritiussufficient evidence for acceptingstatus of residence & beneficial ownership

Delhi High Court 31 May 2002ruled Circular invalid

Indian Supreme Court 7 October 2003ruled in favour of appellants Global Business Institute Ltd & Government of India

India-Singapore CECA

Comprehensive Economic Cooperation Agreement (CECA)

wef 1 August 2005

India-Singapore DTA 1994wef 1 January 1994 (Singapore)wef 1 April 1994 (India)

Protocol to amend 1994 DTAsigned on 29 June 2005wef 1 August 2005

India-Singapore Protocol (1)

Article 3 of Protocol

1. A resident of a Contracting Stateshall not be entitled to the benefits of Article 1 of this Protocolif its affairs were arranged with the primary purposeto take advantage of the benefits in Article 1 of this Protocol.

2. A shell/conduit company that claims it is a resident of a Contracting State shall not be entitled to the benefits of Article 1 of this Protocol. A shell/conduit company is any legal entity falling within the definition of resident with negligible or nil business operationsor with no real and continuous business activitiescarried out in that Contracting State.

3. A resident of a Contracting State is deemed to be a shell/conduit companyif its total annual expenditure on operations in that Contracting State is less than SGD 200,000 or INR 5,000,000 in the respective Contracting Stateas the case may be,in the immediately preceding period of 24 months from the date the gains arise.

4. A resident of a Contracting State is deemednot to be a shelf/conduit company if:

(a) it is listed on a recognised stock exchange of the Contracting State, or

(b) its total annual expenditure on operations in that Contracting Stateis equal to or more than SGD 200,000 or INR 5,000,000 in the respective Contracting State as the case may be, in the immediately preceding period of 24 months from the date the gains arise.

India-Singapore Protocol (2)

PRC DTAs

Div. Int Roy

Hong Kong 5/10% 7% 7%

Barbados 5% 10% 10%

Mauritius 5% 10% 10%

Seychelles 5% 10% 10%

Macau 10% 7/10% 10%

Singapore 7/12% 7/10% 10%

Singapore IRAS

Inland Revenue Authority of Singapore

http://www.iras.gov.sg

Australia

Austria Bahrain Bangladesh Belgium Bulgaria

Canada China Cyprus Czech Republic

Denmark

Egypt

Finland France Germany Hungary India

Indonesia

Israel

I taly

J apan

Korea

Kuwait

Latvia

Lithuaia

Luxembourg

Malaysia

Mauritius

Mexico

Mongolia

Myanmar

Netherlands

New

Zealand

Norway

Oman

Pakistan

Papua New Guinea

Philippines Poland

Portugal Romania

Slovak Republic

South Africa

Sri Lanka

Sweden

Switzerland

Taiwan

Thailand

Turkey

United Arab

Emirates

United

Kingdom

Vietnam

Bahrain

Chile Hong Kong Oman Saudi Arabia

United Arab Emirates

USA

Belgium

Brunei

Estonia

Fiji

Germany

Kazakhstan

Malta

Russian Federation

Singapore DTAs (1)

1. Australia 15(A) 10 10(j)

• Austria 10 / 0 ( 10%)(a) 5(a)(bi) 5

3. Bahrain(Q) 0 5(a) 5

4. Bangladesh 15 10 10(j)

5. Belgium(B) 15 10 5

6. Bulgaria 5(a) 5(a) 5

7. Canada 15 15(bi) 15(o)

8. China 12 / 7 ( 25%)(C) 10(a)(bii)(c) 10

9. Cyprus 0 10(a)(bii)(c) 10

10. Czech Republic 5 0 10

11. Denmark 10 / 5 / 0 ( 25%)(a) 10(a) 10

12. Egypt(D) 15 15(a) 15(o)

13. Finland 10 / 5 ( 10%)(a) 5(a) 5

14. France 15 / 10 ( 10%) 10(a)(bi) 0(j)

15. Germany 15 / 10 ( 25%)(E) 10(a) 0(j)

16. Hungary 10 / 5 ( 25%)(a) 5(a)(bi) 5

17. India 15 / 10 ( 25%)(F) 15 / 10(d) 10

18. Indonesia 15 / 10 ( 25%) 10(a)(bi) 15(o)

19. Israel 0(G) 15 15(k)(o)

20. Italy 10 12.5(a) 20 /15(o)

Dividends (%)* Interest (%) Royalties (%)**

Singapore DTAs (2)

21. Japan 15 / 5 ( 25%) 10(a) 10

22. Korea 15 / 10 ( 25%) 10(a) 15(o)

23. Kuwait 0 7(a) 10

24. Latvia 10 / 5 ( 25%)(a) 10(a) 7.5

25. Lithuania(H) 10 / 5 ( 25%)(a) 10(a) 7.5

26. Luxembourg 10 / 5 ( 10%)(a) 10(a)(I) 10(l)

27. Malaysia(Z) 0(a) 10(a) 8

• Mauritius 0 0 0

• Mexico 0 15(a)(bi)(bii)(e) 10

• Mongolia(J) 10 / 5(a) 10 / 5(a)(bii) 5

31. Myanmar 0 10(a)(bii)(f) 15 / 10(l)(o)

32. Netherlands 15 / 0 ( 25%) 10(a)(K) 0(K)

33. New Zealand 15 15 15(j)(o)

• Norway 15 / 5 ( 25%)(a) 7(a)(L) 7(L)

• Oman 5(a) 7(a) 8

36. Pakistan 10 / 12.5 / 15(M) 12.5(a) 10(j)

37. Papua New Guinea 15 10 10

38. Philippines 25 / 15 (15%)(N) 15(bi) 25 / 15(m)(o)

39. Poland 10 / 0(a) 10(a) 10

40. Portugal 10(P)(a) 10(a)(bi) 10

Dividends (%)* Royalties (%)**Interest (%)

Singapore DTAs (3)

40. Romania 5(Q)(a) 5(a)(bi) 5

41. Slovak Republic 10 / 5 (≥ 10%) 0 10

42. South Africa 15 / 5 ( 10%)(R) (a) 0 5

43. Sri Lanka 15 10(a)(bii) 15(o)

44. Sweden 15 / 10 ( 25%) 15(a)(g) 0(j)

45. Switzerland 15 / 10 ( 25%) 10(h) 5(h)(j)(S)

46. Taiwan 40(T) 20 15(j)(o)

47. Thailand 20 ( 25%)(U) 25 / 10(a)(bii)(U) 15(o)

48. Turkey 15 / 10 ( 25%) 10(a)(i) 10

49. United Arab Emirates(V) 5 7(a) 5(n)

50. United Kingdom 15 / 5 ( 10%)(W) 10(a) 10

51. Vietnam 12.5 / 7/5 (X) 10(a) 15 / 5(o)

Non-treaty Countries 0 15 10(o)

Dividends (%)* Interest (%) Royalties (%)**

* Dividends paid by a company which is a resident of Singapore to a resident of a treaty country are exempt from any tax in Singapore which is chargeable on dividends in addition to tax chargeable in respect of profits or income of the company. The rates shown in this column therefore reflect the position of the other treaty country.

** In certain circumstances, the reduced rates do not apply to royalties for copyrights of literary or artistic works, including cinematographic films and films or tapes for radio or television broadcasting. Reference should be made to the relevant tax treaty.

(A) Under Australian domestic law, no withholding tax is imposed on franked dividends. Consequently for dividends paid by Australian resident companies, the rates in this column apply to unfranked dividends only.

(B) Belgium has signed a supplemental tax treaty with Singapore which came into force with effect from 5 May 2004.

(A) Under China domestic tax law,(i) withholding tax for dividends is 20%;(ii) dividends remitted abroad by foreign investment enterprises and foreign enterprises are exempt from withholding tax.

(D) The treaty signed with Egypt on 22 May 1996 was ratified on 27 January 2004 and is effective in Singapore with respect to taxes on income from the year of assessment 2006 onwards.

(E) A new treaty was signed on 28 June 2004 but this has not been ratified. Under the new treaty, withholding tax rate on dividends is 15 / 5% ( 10%), for interest and royalties it is 8%.

(F) Under Indian domestic law, dividends declared or paid by Indian companies are exempt from tax in the hands of the recipients. However, Indian companies must pay dividend distribution tax at a rate of 14.025% on dividends declared, distributed or paid by them.

(G) Under a disputed interpretation of the treaty, a 15% rate may apply to dividends paid out of the profits of an approved enterprise or property.

(H) The treaty was ratified on 28 June 2004 and is effective in Singapore with respect to taxes on income from year of assessment 2006 onwards.

(I) Under Luxembourg domestic tax law, there is no withholding tax on interest and royalties.

(J) The treaty signed with Mongolia on 10 October 2002 was ratified on22 October 2004 is effective in Singapore from year of assessment 2006 onwards.

(A) Under Dutch domestic law, interest and royalties are not subject to withholding tax.

(B) Under Norwegian domestic law, interest and royalties are not subject to withholding tax.

(M) The 10% rate applies if the payer is engaged in an industrial undertaking and the recipient is a company, the 12.5% rate applies if the recipient is a company, the 15% rate applies in all other cases.

(N) The rate is 15% if the recipient holds at least 15% of the capital of the payer during the two tax years preceding the year of the dividend payment.

(O) The lower rate applies to certain dividends paid to government units or companies.

(P) The 5% substitute gift and inheritance tax was abolished, effective from 2003.

(Q) The treaty signed with Bahrain on 18 February 2004 was ratifiedon 31 December 2004 and is effective in Singapore from year of assessment 2006 onwards.

(A) Dividends are not subject to withholding tax in South Africa.

(B) Under Swiss domestic law, no withholding tax is imposed on royalties, management fees, rents, licences and technical assistance fees etc.

(T) For dividends paid to Singapore residents which beneficially own the dividends, the withholding tax on the dividends and the corporate income tax payable on the profits of the payer may not exceed 40% of the taxable income of the payer out of which the dividends are paid.

(U) Under Thailand domestic law, withholding taxes for dividends and interest are 10% and 15% respectively. The treaty rate for dividends is 20%( 25%) and for interest is 10% (if received by financial institutions) and 25% if otherwise.

(V) Withholding taxes are not imposed in the UAE.

(A) Under United Kingdom domestic law, no withholding tax is imposed on dividends.

(X) (a) 5% if the beneficial owner has contributed, directly or indirectly, more than 50% of the capital of the company paying the dividends or more than US$10 million;

(b) 7% if the beneficial owner has contributed, directly or indirectly, between 25% and 50% of the capital of the company paying the dividends; and

(c) 12.5% of the gross amount of the dividends in all other cases.

(A) The treaty signed with Oman on 6 October 2003 was ratified on 7 April 2006 and is effective in Singapore from year of assessment 2008 onwards.

(A) The new agreement signed with Malaysia on 5 October 2004 was ratified on 13 February 2006 and is effective in Singapore in respect of taxes on income from year of assessment 2008 onwards.

(a) Exempt if paid to the government of the other state.(a) (i) Interest is exempt under certain specified circumstances. (ii) The lower rate applies if the interest is received by a bank or similar financial institution.(c) The rate is 7% for interest paid to banks or other financial institutions.(d) The 10% rate applies to interest paid to financial institutions.

The 15% rate applies to other interest.(e) The rate is 5% for interest paid to banks.(f) The rate is 8% for interest paid to banks or other financial institutions.(g) The rate is 10% for interest paid by industrial undertakings

to financial institutions in Sweden.(h) No withholding tax applies to interest or royalties

with respect to certain approved transactions.(i) The rate is 7.5% for interest paid to financial institutions.(j) Royalties on literary or artistic copyrights, including film royalties, are taxed at non-treaty rates.(k) The tax rate on the royalties in the recipient’s country is limited to 15% under the treaty.(l) The 10% rate applies to payments relating to patents, designs, models, plans, secret formulas or

processes, and to industrial, commercial or scientific equipment or experience. The 15% rate applies to payments for all other cases.

(a) The rate is 15% if the royalties are paid by a Board of Investment registered preferred enterprise or for royalties paid for copyrights of literary, artistic or scientific works.

Royalties approved under the Economic Expansion Incentives (Relief from Income Tax) Act are exempt.• This rate does not apply to royalties with respect to the operation of mines or quarries or

the exploitation of natural resources. A contracting state may exempt or reduce the tax on industrial royalties in accordance with its domestic laws.

• Royalties derived from Singapore are subject to a final tax of 10% with effect from 1 January 2005.

Singapore Pte Ltd

Section 17 Companies Act (Cap. 50)

one subscriber

Section 142(1) CA

A company shall as from the date of its incorporationhave a registered office within Singapore.

Second Schedule CA

Registration fee SGD 300

Director & Secretary

Section 145(1) CA

Every company shall have at least one director who is ordinarily resident in Singapore and, where the company only has one member, that sole director may also be the sole member of the company.

Section 145(2) CA

No person other than a natural personof full age and capacity shall be a director of a company.

Section 171(1) CA

Every company shall have one or more secretaries each of whom shall be a natural person who has his principal or only place of residence in Singapore.

Section 171 (1E)

Where a director is the sole director of a company, he shall not act or be appointed as the secretary of the company.

Section 205C(1)

An exempt private company shall be exempt from audit requirements

in respect of a financial year if its revenue in that year does not exceed the prescribed amountof SGD 5 million (in respect of a financial year from 1 June 2004)

exempt private company meansa private company in the shares of whichno beneficial interest is held directly or indirectlyby any corporationand which has not more than 20 members

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