Singapore continually reviews its international tax policy to ensure its economy remains competitive. The policy aims to strengthen bilateral investment flows, thereby supporting Singapore-based businesses to expand overseas and reach out to a wider pool of international customers.
As a responsible international tax jurisdiction, Singapore also has in place an active policy of international tax co-operation to prevent and tackle cross border tax evasion.
Singapore’s international tax policy is conducted primarily through aspects of domestic law governing international taxation, avoidance of double taxation agreements and other agreements providing for international tax cooperation.
To view all Press Releases and Announcements on Singapore's bilateral tax treaties, click here.
International Tax Cooperation
Singapore does not condone cross-border tax evasion.
- Singapore adopts internationally accepted transfer pricing guidelines. Businesses are to adopt these guidelines and ensure that profits allocated are commensurate with the associated functions, assets and risks in Singapore. Our laws require businesses to maintain contemporaneous records to demonstrate their compliance with the transfer pricing guidelines. Singapore also runs a well-established programme for bilateral advance pricing agreements with our treaty partners to ensure that transactions of businesses with related parties are priced in accordance with the Arm’s Length Principle.
- Singapore is also committed to international tax cooperation. We have and will continue to assist tax authorities to the fullest extent possible. To this end, Singapore adopts the internationally agreed standards for exchange of information.
- Singapore actively works with other jurisdictions, OECD and G20 to counter Base Erosion and Profit Shifting (BEPS). Coordinated global efforts are important for a common set of rules to be applied across tax jurisdictions, thereby ensuring a level playing field so that tax jurisdictions, large or small, developed or developing, can compete fairly based on their fundamental advantages. This also ensures certainty of international taxation rules for cross-border transactions, so as to avoid double taxation and promote global growth. Singapore’s response to OECD’s recommendations to counter BEPS can be accessed here.
Internationally-agreed Standards for Exchange of Information (EOI)
Singapore endorsed the internationally-agreed Standard for Exchange of Information (EOI Standard) in 2009. The EOI Standard sets out how tax jurisdictions should address cross-border tax evasion by entering into effective information sharing arrangements. Since 2009, Singapore has been updating and increasing its network of treaties to be in line with the EOI Standard. In line with developments in international standards and practices, Singapore made further changes in 2013 to strengthen our EOI regime. Details of these changes are in this press release. Singapore’s exchange of information upon request regime has been rated as compliant with international tax transparency standards, by the Global Forum on Transparency and EOI for Tax Purposes. This is the highest overall rating a jurisdiction can receive. Please refer to this link for more information.
In 2014, Singapore, along with other major financial centres, committed to implement the Common Reporting Standard for Automatic Exchange of Financial Account Information (AEOI) by 2018, after it has been endorsed by the G20 as a new global standard. Singapore's implementation of AEOI remains guided by the following principles:
Singapore will be able to implement AEOI if it is adopted in all key financial centres in Europe and Asia, to avoid regulatory arbitrage;
AEOI also needs to be done within a robust framework of law to protect taxpayer confidentiality and ensure that the information is used properly. This is particularly important as AEOI entails the transmission of sensitive taxpayer information which should be safeguarded; and
There is reciprocity with any future AEOI partners in terms of information exchanged.
Please refer to this link for MOF’s response on AEOI.
In September 2018, Singapore commenced AEOI with over 60 jurisdictions.
Convention on Mutual Administrative Assistance in Tax Matters (“Convention”)
Singapore became a signatory of the Convention on 29 May 2013. The Convention was first developed as an OECD-Council of Europe agreement in 1988. It was opened to non-members in 2010. The Convention has been gaining acceptance as an international agreement for bilateral tax cooperation among its signatories and covers several areas of cooperation, including EOI. Singapore deposited its instrument of ratification for the Convention on 20 January 2016. The press release on Singapore’s ratification can be accessed here.
Regulations On The Standard For Automatic Exchange Of Financial Account Information In Tax Matters Published
The Income Tax (International Tax Compliance Agreements) (Common Reporting Standard) Regulations 2016 (“Regulations”) were published on 2 December 2016. A copy of the Regulations can be found on the Inland Revenue Authority of Singapore’s (IRAS) website (https://www.iras.gov.sg/IRASHome/CRS/).
The Regulations allow Singapore to implement the Standard for Automatic Exchange of Financial Account Information in Tax Matters (“AEOI”), also known as the Common Reporting Standard (“CRS”), with effect from 1 January 2017 .
The CRS is an internationally agreed standard for AEOI, endorsed by the OECD and the Global Forum for Transparency and Exchange of Information for Tax Purposes. The CRS sets out the financial account information to be exchanged, the financial institutions (“FIs”) required to report, the different types of accounts and taxpayers covered, as well as the customer due diligence procedures to be followed by the financial institutions. More than 100 jurisdictions, including major financial centres such as Hong Kong, Luxembourg and Switzerland, have endorsed the CRS and have commenced AEOI in either 2017 or 2018. Singapore has committed to implement the CRS and the first exchange took place in In September 2018.
 The Regulations will require all financial institutions to put in place necessary processes and systems to collect CRS information from all non-Singapore tax resident account holders (known as the “Wider Approach”) from 1 January 2017. Such collection of information by FIs is necessary in order for FIs to submit the required information to IRAS in 2018, for subsequent exchange under the CRS. This timeline is in accordance with Singapore’s commitment to commence first exchange of information under the CRS in 2018.
Singapore-US Foreign Account Tax Compliance Act Intergovernmental Agreement and Regulations Enter into Force
The Singapore-US Foreign Account Tax Compliance Act (FATCA) Model 1 Intergovernmental Agreement (IGA) and Regulations entered into force on 18 March 2015. A copy of the agreement and Regulations can be found on the Inland Revenue Authority of Singapore’s (IRAS) website.
FATCA is a US law which targets non-compliance with tax laws by US persons using overseas accounts. Under FATCA, all financial institutions (FIs) outside of the US are required to regularly submit information on financial accounts held by US persons to the US Internal Revenue Service (IRS). The Singapore-US IGA facilitates Singapore-based FIs’ compliance with FATCA, by allowing them to fulfil their reporting obligations through the IRAS instead of reporting directly to the US IRS.
 The IGA and Regulations can be found at: https://www.iras.gov.sg/irasHome/fatca/
 The FATCA 9 December 2014 press release can be found here
The FATCA 22 September 2014 press release on our proposed Regulations and e-Tax Guide can be found here
Tax Treaties (Double Taxation Agreements)
Singapore's Avoidance of double taxation agreements (DTAs)
DTAs help to promote bilateral investment and trade flows. Through the provisions of a DTA, taxpayers engaged in cross-border business can enjoy certainty on the taxing rights of either jurisdiction, benefit from the elimination of double taxation, and gain access to a platform to settle tax disputes.
Currently, Singapore has more than 80 comprehensive DTAs in force. The full list of Singapore’s DTAs can be found on IRAS’ website.
Frequently Asked Questions (FAQs) on DTAs
What is a DTA?
A DTA is a bilateral agreement which provides clarity on the taxing rights of each contracting jurisdiction on all forms of bilateral income flows. The DTA also eliminates instances of double taxation which can arise from cross-border trade and investment activities. Usually, there would be provisions in the DTA for reduction or exemption of tax at source on certain types of cross-border incomes such as interest and royalties.
How are DTAs negotiated?
As with any other bilateral treaty, there would have to be mutual interest from both jurisdictions before formal negotiations can be established. While it is expected for each jurisdiction to push for terms that best serve its interests, compromises would have to be made to achieve an overall balance of benefits. Both sides may require more than one round of face-to-face meetings to resolve all outstanding issues and finalise the terms of the DTA.
Upon the conclusion of negotiations, both jurisdictions would arrange for the DTA to be signed by the relevant authorities. Following the signing, both jurisdiction would have to ratify the DTA before it enters into force.
How do I seek assistance if I encounter a problem relating to the application of a particular DTA?
The Mutual Agreement Procedure (MAP) Article of a DTA sets out the process to resolve issues relating to the application of the DTA.
Taxpayers who wish to take up their issues under the MAP should approach the tax authority of the State in which they are a tax resident.
More information on the MAP can be found on IRAS’ website.
What is the Multilateral convention to Implement Tax Treaty Related Measures to Prevent Base Erosion and Profit Shifting (“MLI”)?
The MLI allows jurisdictions to swiftly amend their DTAs to implement the tax treaty-related Base Erosion and Profit Shifting (BEPS) recommendations. The MLI also improves the dispute resolution mechanisms in DTAs.
In line with Singapore's commitment to implement the internationally-agreed standard on preventing treaty abuse, Singapore ratified the MLI on 21 December 2018. The MLI entered into force for Singapore on 1 April 2019.
More information on the MLI can be found on IRAS’ website.