International Tax
Singapore’s international tax policies aim to strengthen international trade and investment flows, create the conditions for economic growth and jobs, and support Singapore-based businesses’ expansion overseas, while aligning with international standards.
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What is our approach towards international tax?
Singapore continually reviews our international tax policies to ensure that they remain relevant. As a responsible international tax jurisdiction, Singapore complies with international standards and supports international tax co-operation to prevent and tackle cross-border tax evasion and profit shifting. Our international tax policies are effected through:
Domestic law governing international taxation,
Avoidance of double taxation agreements, and
Other agreements providing for international tax cooperation.
International Tax Co-operation
Efforts to counter Base Erosion and Profit Shifting (BEPS)
Singapore adopts internationally accepted transfer pricing guidelines. Businesses must adhere to 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 multilateral and bilateral advance pricing arrangements with our treaty partners to ensure that transactions of businesses with related parties are priced in accordance with the Arm’s Length Principle.
As a member of the Inclusive Framework on Base Erosion and Profit Shifting (BEPS), the multilateral body that sets internationally agreed standards to combat BEPS and assesses jurisdictions’ implementation of these standards, Singapore actively works with other jurisdictions, the OECD and the G20 to counter BEPS. Coordinated global efforts based on sound principles are important for a common set of rules to be applied across jurisdictions, to ensure a level playing field so that jurisdictions, large or small, developed or developing, can compete fairly based on their fundamental advantages and businesses can continue to innovate and grow. This also ensures certainty of international taxation rules for cross-border transactions, to avoid double taxation and promote global growth:
Singapore has implemented all the internationally agreed standards for combating BEPS. Singapore’s implementation of these standards is reviewed by the Inclusive Framework on BEPS. For instance, our tax incentive schemes have been assessed by the Forum on Harmful Tax Practices (FHTP) as compliant with internationally agreed standards for countering harmful tax practices.
Singapore has signed and ratified the following multilateral agreements developed by the Inclusive Framework on BEPS:
The Multilateral Convention to Implement Tax Treaty Related Measures to Prevent BEPS (MLI), which updates Singapore’s tax treaties with the internationally agreed standards to counter treaty abuse and improve dispute resolution. Singapore signed and ratified the MLI on 7 June 2017 and 21 December 2018 respectively. The MLI entered into force for Singapore on 1 April 2019.
The Multilateral Competent Authority Agreement (MCAA) on the Exchange of Country-by-Country (CbC) reports.
💡 Please refer to IRAS’ website for more information on the MLI and the MCAA on the Exchange of CbC reports.
Internationally agreed Standards for Exchange of Information (EOI)
Singapore abides by the internationally agreed standards for EOI for tax transparency. Singapore is a member of the Global Forum on Transparency and EOI for Tax Purposes (Global Forum), the multilateral body working on the effective implementation of internationally agreed standards for tax transparency.
Singapore endorsed the internationally agreed Standard for EOI (EOI Standard) in 2009. The EOI Standard sets out how 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.
Singapore’s EOI upon request regime has been rated as compliant with international tax transparency standards by the Global Forum. This is the highest overall rating a jurisdiction can receive (details in this press release).
In 2014, Singapore, along with other major financial centres, committed to implement the Common Reporting Standard (CRS) for the automatic exchange of financial account information (AEOI), after it was endorsed by the G20 as a new global standard. The CRS sets out the financial account information to be exchanged, the financial institutions 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.
Singapore's implementation of AEOI is guided by the following principles:
AEOI will only be effective if it is adopted in all key financial centres in Europe and Asia, to avoid regulatory arbitrage;
AEOI 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; and
There should be reciprocity.
Singapore has signed and ratified the Multilateral Competent Authority Agreement on Automatic Exchange of Financial Account information under the CRS (CRS MCAA), and published regulations to implement the CRS.
In September 2018, Singapore commenced AEOI with over 60 jurisdictions, and has since activated AEOI relationships with more than 100 jurisdictions.
Singapore also signed the Multilateral Competent Authority Agreement on Automatic Exchange of Information Pursuant to the Crypto-Asset Reporting Framework (CARF) and the Addendum to the CRS MCAA on 26 November 2024, and is working towards commencing exchanges under these agreements in 2028.
💡 Please refer to IRAS’ website for further information on CRS and CARF.
Regulations on the Standard for the Automatic Exchange of Financial Account Information in Tax Matters
The Income Tax (International Tax Compliance Agreements) (Common Reporting Standard) Regulations 2016 (Regulations) were published on 2 December 2016.
The Regulations incorporates the Common Reporting Standard (CRS) for the automatic exchange of financial account information with effect from 1 January 2017 under Singapore’s domestic legislative framework, and require all financial institutions to put in place necessary processes and systems to collect CRS information from all non-Singapore tax resident account holders from 1 January 2017.
More than 100 jurisdictions, including major financial centres such as Hong Kong, Luxembourg and Switzerland, have endorsed the CRS and have commenced AEOI.
The Regulations will be updated in due course to bring into effect the Addendum to the CRS MCAA.
💡 Please refer to IRAS’ website for a copy of the Regulations.
Singapore-US Foreign Account Tax Compliance Act Intergovernmental Agreement and Regulations
The agreement reached between Singapore and the US to improve international tax compliance and to implement the Foreign Account Tax Compliance Act (FATCA) (the Singapore-US FATCA Agreement) and the Regulations to incorporate the agreement into Singapore’s domestic legislative framework entered into force on 18 March 2015. The updated Singapore-US FATCA Agreement and the Regulations entered into force on 1 January 2021.
FATCA is a US law which targets non-compliance with tax laws by US persons using non-US accounts. Under FATCA, all financial institutions outside of the US are required to regularly submit information on financial accounts held by US persons to the US Internal Revenue Service (IRS) or be subject to withholding tax on certain payments. The Singapore-US FATCA Agreement facilitates Singapore-based financial institutions’ compliance with FATCA, by allowing them to fulfil their reporting obligations through the IRAS instead of reporting directly to the US IRS.
💡 Please refer to IRAS’ website for further information about the Singapore-US FATCA Agreement.
The Multilateral 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 and covers several areas of cooperation, including EOI upon request, spontaneous EOI and AEOI.
Singapore deposited its instrument of ratification for the Convention on 20 January 2016 (details in this press release and on OECD’s website).
Singapore’s Avoidance of Double Taxation Agreements (DTAs)
💡A DTA is a bilateral agreement which provides clarity on the taxing rights of each contracting jurisdiction on all forms of bilateral income flows. It seeks to eliminate instances of double taxation which can arise from cross-border trade and investment activities. DTAs may provide for the reduction or exemption of tax at source on certain types of cross-border incomes such as interest and royalties.
DTAs help to promote bilateral investment and trade flows.
DTAs allow taxpayers engaged in cross-border business to enjoy certainty on the taxing rights of either jurisdiction and benefit from the elimination of double taxation.
DTAs provide a platform to settle tax disputes.
Singapore has an extensive network of DTAs.
How are DTAs negotiated?
To commence DTA negotiation, both jurisdictions must first have mutual interest.
Each jurisdiction will push for terms that best meet its interests but eventually compromises will be made to achieve an overall balance of benefits.
Once negotiations conclude, both jurisdictions will arrange for the DTA to be signed by the relevant authorities.
After signing, both jurisdictions will have to ratify the DTA according to their domestic law and provisions of the DTA before it enters into force.
How are disputes resolved?
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.
💡 Please refer to IRAS’ website for more information about the Mutual Agreement Procedure.
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 internationally agreed tax treaty-related Base Erosion and Profit Shifting (BEPS) standards to counter treaty abuse. The MLI also improves the dispute resolution mechanisms in DTAs.
In line with Singapore's commitment to implement these internationally agreed standards, Singapore signed and ratified the MLI on 7 June 2017 and 21 December 2018 respectively. The MLI entered into force for Singapore on 1 April 2019.
💡 Please refer to IRAS’ website for more information about the MLI.
More information about Singapore’s Avoidance of Double Taxation Agreements:
Read the press releases and details of all Singapore’s DTAs.
