Singapore Withholding Tax and Double Tax Agreement (DTA)

Domestic corporations paying certain types of income to non-residents are required to withhold tax.

Unless a lower treaty rate applies, interest on loans and rentals from movable property are subject to WHT at the rate of 15%. Royalty payments are subject to WHT at the rate of 10%. The tax withheld represents a final tax and applies only to non-residents who are not carrying on any business in Singapore and who have no PE in Singapore. Technical assistance and management fees for services rendered in Singapore are taxed at the prevailing corporate rate. However, this is not a final tax. Royalties, interest, rental of movable property, technical assistance, and management fees can be exempt from WHT in certain situations or subject to a reduction in tax rates, usually under fiscal incentives or DTAs.

Payments made to public entertainers and non-resident professionals who perform services in Singapore are also subject to a final tax of 15% on their gross income. For public entertainers, this appears to be a final tax unless they qualify to be taxed as Singapore tax residents. However, non-resident professionals may elect to be taxed at the prevailing tax rate for non-resident individuals of 22% on net income if this results in a lower tax cost. The WHT rate on payments to non-resident entertainers was reduced to 10% from 22 February 2010 to 31 March 2020.

Ship charter fee payments are not subject to WHT.

The WHT rates are shown in the following table.

Notes

1. Singapore has no WHT on dividends over and above the tax on the profits out of which the dividends are declared. However, some treaties provide for a maximum WHT on dividends should Singapore impose such a WHT in the future.

2. The non-treaty rates (a final tax) apply only to non-residents who do not carry on business in Singapore and who do not have a PE in Singapore. This rate may be further reduced by tax incentives.

3. Interest:
   1. Lower rate or exemption if received by a financial institution.
   2. Exempt if paid to the government.
   3. Lower rate or exemption if paid by an approved industrial undertaking.
   4. Exempt if paid by a bank and received by a bank.
   5. Exempt if paid to a bank but linked to a government loan agreement or paid to specific financial institutions/banks.
   6. Exempt if paid in respect of an approved loan or indebtedness.
   7. Exempt if paid to an approved pension fund.
   8. Lower rate if paid to a financial institution or insurance company or paid with respect to indebtedness arising from a sale on credit of any equipment, merchandise, or services.
   9. Exempt if paid by a financial institution.
   10. Exempt if paid by the government.
   11. Exempt if paid in respect of a loan, debt-claim, or credit that is guaranteed or insured by the government.
   12. Exempt if paid in respect of any debt instrument listed on a recognised stock exchange.
4. Royalties:
   1. Royalties on literary or artistic copyrights, including film royalties, are taxed at the non-treaty rate.
   2. Lower rate for payments in connection with industrial, commercial, or scientific equipment.
   3. Royalties on literary, artistic, or scientific work, except computer software, but including film royalties, are exempt.
   4. Lower rate of 5% for royalties on copyright of literary, artistic, or scientific work, including cinematograph films, or films or tapes used for radio or television broadcasting, and 8% for royalties in connection with patents, trademarks, designs or model, plan, secret formula, or process, or industrial, commercial, or scientific equipment.>
   5. Lower rate on copyright of literary, artistic, or scientific work, including cinematograph films, or films or tapes used for radio or television broadcasting.
   6. Lower rate for payments in connection with patents, designs, secret formulas/processes, or industrial, commercial, or scientific equipment/experience.
5. Treaties:
   1. Treaty with Bermuda covers only the exchange of information.
   2. Treaty with Chile covers only international ship operations.
   3. Treaties with Brazil, Hong Kong, and the United States cover only shipping and air transport activities.
   4. Treaty or lower rate applies from 1 January 2018.

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