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Tax advisory and planning
in Singapore.

We advise foreign-owned entities, regional headquarters, and growing businesses on structuring their Singapore tax position efficiently, from initial setup through to cross-border transactions and expansion. We analyse your current tax profile, identify inefficiencies, and help you make well-informed decisions before you commit to a structure, investment or transaction.

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Tax advisory & planning in Singapore

Minimise your tax liability and boost business profitability.

Tax structure review

We analyse your current tax position, identify inefficiencies and assess whether your entity is making full use of available exemptions, incentives and treaty benefits.

Tax incentives

We identify the incentives your entity qualifies for, including schemes administered by EDB, MPA and IRAS, and manage the application process on your behalf.

Cross-border tax planning

For businesses operating across multiple jurisdictions, we advise on structuring for regional operations, double tax treaty applications and efficient profit repatriation.

Corporate and personal tax advisory

Making your business truly tax efficient.

Corporate tax.

  • Corporate tax advisory

    We advise on the most efficient way to set up a company, including the shareholding structure, and analyse the tax implications of transactions under consideration, whether contracts, investments, acquisitions or restructurings.

    Our team conducts corporate tax planning reviews to identify savings opportunities, reliefs, exemptions and incentive eligibility, and manages the application process for available incentives, including sector-specific schemes administered by EDB, MPA, and IRAS.

    Where clarity from the authorities is required, we also support advance rulings and technical position management.

  • Cross-border and international tax planning

    For businesses operating across multiple jurisdictions, we advise on inbound and outbound investment structuring, regional tax reviews, and group structuring. Our treaty planning work includes support for accessing treaty benefits and managing Certificate of Residence applications.

    We also provide withholding tax advisory for offshore payments and keep clients informed of emerging international tax developments, including BEPS-related considerations and digital tax exposure.

  • Transaction and restructuring advisory

    We support clients through the full transaction lifecycle, from buy-side and sell-side tax due diligence through to M&A tax structuring and integration planning. Our work also covers reorganisations and reconstructions, including group simplification and post-transaction restructuring.

  • Transfer pricing advisory

    Our transfer pricing advisory work covers planning, design, and policy setting for intercompany pricing models, service charges, and financing arrangements. We conduct risk reviews and provide readiness support ahead of audits and enquiries, and assist with:

    • Audit support, dispute resolution and Advance Pricing Agreement (APA) negotiations
    • Preparation of master files, local files and country-by-country reports where documentation is required

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  • Indirect tax (GST) advisory

    We provide GST advisory and transactional review across products, services and cross-border arrangements, including classification guidance on taxable, exempt and zero-rated supplies. Our GST health-checks and risk assessments help clients identify exposure and strengthen the controls underpinning their GST position.

  • Tax enquiries, disputes and voluntary disclosures

    We advise on and manage tax enquiries and audits, draft responses to authority queries, and support negotiations with a focus on commercially sound outcomes. Where historic filing positions require correction, we prepare voluntary disclosures and remediation plans. We also assist with:

    • Objections and appeals
    • Mutual agreement procedures

  • CRS and FATCA

    When a company opens a bank account, the bank will require the company to make a statement as to the company’s status under either CRS or FATCA. A CRS statement will be required from any entity whose beneficial owners are no U.S. citizens. A FATCA statement will be required where any beneficial owners are U.S. citizens. The classification process is far from straightforward, with the bank’s how-to guides stretching to 20 pages or more. An Acclime professional can assist with the correct classification for your company.

    What is CRS and FATCA?

    CRS and FATCA.

    The Common Reporting Standard (CRS) is an information standard for the Automatic Exchange Of Information (AEOI) regarding bank accounts on a global level, between tax authorities. It was developed by the Organisation for Economic Co-operation and Development (OECD) in 2014 to combat tax evasion.

    The Foreign Account Tax Compliance Act (FATCA) generally requires financial institutions (FI) and certain other non-financial entities that are foreign to the U.S. to report on assets held by their U.S. account holders or be subject to withholding on withholdable payments.

    CRS classifications

    There are three categories of classification of companies under CRS. The category will determine whether a bank is required to report the existence of the account to the Indonesian Director General of Tax (DGT), who would then share the information with the tax authority where the beneficial owner is tax resident.

    A. Business size exemption – meet 2/3 criteria below:
    • Financial institution (FI) – An FI is an investment entity (managing investments on behalf of others), a custodial entity, a depository institution or a specified insurance company. Each of these definitions have several subparts making the classification somewhat complex.
    • Active non-financial institution (Active NFI) – This is a company that is not a FI but carries on an active business, and not more than 50% of its assets are passive assets (e.g. money sitting in a bank account). For operating companies, most will fall in this classification, unless they have substantial bank balances (e.g. from profits not yet distributed).
    • Passive non-financial institution (Passive NFI) – This is a company that is not an Active NFI.
    B. Related party transaction value-based exemption:
    • Transfer of property (excluding financial assets and intangibles) < HK$220 million (US$28.4 million)
    • Transactions of Financial Assets < HK$110 million (US$14.2 million)
    • Transfer of Intangibles < HK$110 million (US$14.2 million)
    • Any other transactions < HK$44 million (US$5.68 million)

    If the company is not exempt, it must prepare the following documentation as stipulated by OECD:

    • Master file: provides a high-level overview of the multinational’s global operations and value chain
    • Local file: provides detailed analysis of the local entity’s operations and transfer pricing practices
    • Country by country report: provides a wide range of specific information regarding the value chain and operations of the multinational as a whole

    Depending on your entity’s classification, and where it’s resident for tax purposes, it may be a Reportable Person. That means details of the account will be reportable to the tax authority in Indonesia. That authority will then send your details to the tax authority where your entity or controlling person(s) is/are tax resident.

    Financial institution – Not reportable

    Active NFI – The entity is a reportable entity unless it falls in one of the exemptions (e.g. government-owned, regularly traded on an exchange, charity)

    Passive NFI – The entity is a reportable entity, as is the controlling person(s) of the Passive NFI

    If reporting is required, the person’s name, tax ID number and account balance must be reported as well as any dividends, interest or sales proceeds from financial assets that have been paid into the account during the year.

    As the classification process is quite complicated and there are penalties for getting it wrong, it is advisable to have professional advice regarding the classification of your company. Acclime’s tax experts will be able to assist and advise you as to the correct classification of your company.

    FATCA Classification

    Although the definitions under FATCA and CRS are similar, there are differences which could cause your company to have a different FATCA classification from its CRS classification.

    Indonesia has signed an Inter-Governmental Agreement (IGA) with the U.S. as regards FATCA, so banks in Indonesia need to comply with the reporting obligations.

    FATCA has three categories of company:

    • Financial institution (FI)- This is very similar to the CRS FI definition, but also includes holding companies and treasury centres of financial groups.
    • Non-financial foreign entity (NFFE) – A NFFE is a company that is not a FI but carries on an active business, and not more than 50% of its assets are passive assets (e.g. money sitting in a bank account). For operating companies, most will fall in this classification, unless they have substantial bank balances (e.g. from profits not yet distributed). This is the same definition as Active NFI under CRS.
    • Passive NFFE – This is an entity that is not an NFFE.

    The reporting obligations are similar to CRS for the above entity classifications, with the form that needs to be completed differing based on the classification, and in many cases sub-classification of the entity.

    The classification process is quite complex, and there are penalties for getting it wrong, it is advisable to have professional advice regarding the classification of your company. Our tax experts will be able to assist and advise you as to the correct classification of your company.

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Personal tax.

  • Personal and mobility-related tax advisory

    We provide individual tax advisory and planning for business owners and key employees, including tax planning for in-bound expatriates and secondment arrangements. Our work covers the development of tax-effective remuneration and incentive structures, including share incentives and stock options, as well as employer compliance reviews and tax equalisation policy support.

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FAQs

Common questions and answers.

What does Singapore’s economic substance requirement mean for companies claiming tax benefits?

Singapore’s tax benefits, including foreign-sourced income exemptions, incentive schemes and treaty access, are not available by virtue of incorporation alone. IRAS requires that the activities generating the relevant income are genuinely performed in Singapore by staff with the appropriate skills and authority.

For holding companies and regional headquarters, this means key management decisions must take place in Singapore rather than being directed from an overseas parent. Control and management exercised elsewhere can result in loss of tax residency, denial of treaty benefits and reclassification of exempted income as taxable. Substance requirements have become more significant under BEPS-related reforms and the global minimum tax framework introduced under Pillar Two, and should be assessed at the point of structuring rather than retrospectively. For further detail on how substance interacts with Singapore’s incentive schemes, see our tax incentives guide.

How does Singapore’s territorial tax system work for foreign-sourced income?

Singapore taxes income sourced in Singapore and foreign-sourced income when it is received here. Income earned and retained overseas is generally not taxable until remitted. Tax resident companies may qualify for exemption under the Foreign-Sourced Income Exemption scheme, which covers foreign dividends, foreign branch profits and foreign-sourced service income, subject to specified conditions.

Foreign disposal gains received in Singapore may also become taxable where a multinational group lacks sufficient economic substance in Singapore, a consideration that has grown in relevance under BEPS-related guidance. Where exemptions do not apply, double taxation relief may still be available through Singapore’s treaty network or unilateral tax credits. For further detail, see our guide to taxation of foreign-sourced income.

What withholding tax applies to payments made by Singapore companies to overseas parties?

Withholding tax applies when a Singapore company makes certain payments to non-residents. The payer must deduct the applicable rate and remit it to IRAS by the 15th of the second month after the payment date. Payments commonly subject to withholding tax include:

  • Interest, commissions and fees on loans: 15%
  • Royalties and payments for use of intellectual property: 10%
  • Technical assistance and service fees for services physically rendered in Singapore: 17%
  • Management fees paid to overseas entities: 17%
  • Director fees paid to non-resident directors: 24%
  • Rent on movable property: 15%

Where Singapore has a double taxation agreement with the recipient’s jurisdiction, reduced or zero rates may apply if the overseas party supplies a valid Certificate of Residence. Late payment attracts a 5% penalty plus additional charges. For a full breakdown of rates and exemptions, see our withholding tax guide.

What transfer pricing documentation do Singapore companies with related-party transactions need to prepare?

Singapore requires transactions between related parties to be conducted on an arm’s length basis under the Income Tax Act and IRAS Transfer Pricing Guidelines, which are aligned with the OECD three-tier documentation framework. Companies with gross revenue exceeding SGD 10 million are generally required to prepare transfer pricing documentation by the tax return filing deadline.

Documentation typically includes a local file covering the Singapore entity’s related-party transactions and pricing methodology, and where applicable, a group master file for entities that are part of a larger multinational group. Records must be retained for at least five years and prepared contemporaneously rather than created retrospectively in response to an audit. IRAS may adjust taxable income and impose surcharges where transactions are not conducted on arm’s length terms. See our transfer pricing guide for further detail on documentation requirements.

How does Singapore’s double tax treaty network reduce tax on cross-border payments?

Singapore has concluded more than 100 double taxation agreements covering most major trading and investment jurisdictions. Treaty benefits are generally available only to Singapore tax resident companies, with residency determined by where control and management are exercised, commonly where board meetings and strategic decisions take place.

To claim treaty benefits overseas, Singapore companies may obtain a Certificate of Residence from IRAS and provide it to the relevant foreign tax authority. Where no treaty applies, unilateral tax credits may still reduce double taxation on the same income. For country-specific treaty coverage, see our double tax agreements guide.

What tax incentives are available to companies operating in Singapore?

Singapore offers a range of incentives for companies conducting substantive economic activities here, administered by the Economic Development Board and IRAS depending on the scheme. The main programmes are:

  • Pioneer Certificate Incentive: full tax exemption on qualifying income for five to fifteen years, for companies introducing high-value or technology-intensive activities not previously conducted in Singapore
  • Development and Expansion Incentive: concessionary rates of 5%, 10% or 15% on qualifying expansion income for up to ten years, extendable to a maximum of forty years
  • Global Trader Programme: concessionary rates of 5%, 10% or 15% on qualifying income for international commodity trading and derivatives activity
  • Refundable Investment Credit: introduced in Budget 2024, providing a tax credit of up to 50% of qualifying expenditure in key economic sectors, with unused credits refunded in cash
  • Enterprise Innovation Scheme: 400% tax deductions on qualifying R&D, IP registration, employee training and AI expenditure, administered by IRAS

All incentives require an application and negotiation process with the relevant agency and genuine economic substance in Singapore. For a full overview, see our tax incentives guide.

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Faith Garcia, Regional Business Development Manager
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