Singapore
Corporate - Income determination
Last reviewed - 30 May 2024Inventory valuation
There are no special rules as to which valuation basis should be adopted for inventories (stock-in-trade) in the case of a continuing business, as long as the basis is consistent from one year to another. However, a last in first out (LIFO) basis of valuation is not permitted for tax purposes. Generally, tax reporting conforms to book reporting.
Inventory that is appropriated on or after 16 November 2021 for a purpose other than for sale or disposal in the ordinary course of the trade or business is treated as having been sold at open market value (except for approved donations).
Capital gains
There is no tax on capital gains. Where there is a series of transactions or where the holding period of an asset is relatively short, the tax authorities may take the view that a business is being carried on and attempt to assess the gains as trading profits of the corporation. The United Kingdom (UK) Badges of Trade, which are used in judicial decisions to distinguish capital and revenue transactions, are generally applied in determining this issue. They include the existence of a profit-seeking motive, the number of transactions, the nature of the asset, the existence of similar trading transactions or interests, the way the sale was carried out, the source of finance, the interval of time between purchase and sale, and the method of acquisition.
Gains derived by a company from the disposal of ordinary shares that take place between 1 June 2012 and 31 December 2027 will not be taxed if the company has held at least 20% of the ordinary shares in the investee company for a continuous period of at least 24 months prior to the disposal. This protection does not apply to gains derived by an insurance company or disposal of shares in certain companies that trade or hold immovable properties, as well as disposal on or after 1 June 2022 of unlisted shares in companies in the business of trading, holding, or developing immovable properties in Singapore or abroad.
Notwithstanding the foregoing, gains from the disposal of foreign assets on or after 1 January 2024 by any legal person (other than an individual), general partnership, limited partnership, or trust that does not meet the requisite economic substance requirements and is a member of a relevant group (i.e. its assets, liabilities, income, expenses, and cash flows are included in consolidated financial statements prepared by the parent entity of the group) are taxable when received in Singapore. For further details on foreign-sourced income and the availability of foreign tax credit, refer to Foreign income below.
Dividend income
Singapore dividends are exempt in the hands of the recipient.
Interest income
Singapore-sourced interest income is taxable when it arises, and foreign-sourced interest is taxable when it is received in Singapore. For further details on foreign-sourced interest income and the availability of foreign tax credit, refer to Foreign income below.
Royalty income
Singapore-sourced royalty income is taxable when it arises, and foreign-sourced royalty income is taxable when it is received in Singapore. For further details on foreign-sourced royalty income and the availability of foreign tax credit, refer to Foreign income below.
Foreign income
A corporation, whether resident in Singapore or not, is taxed on foreign income when it is received in Singapore. Legislative provisions govern the basis of treating foreign income as received in Singapore. There are no special rules for taxing the undistributed income of foreign subsidiaries.
Where income is earned from treaty countries, double taxation is avoided by means of foreign tax credit granted under those treaties. For non-treaty countries, unilateral tax credit is given in respect of foreign tax on all foreign-sourced income. These foreign tax credits may be pooled, subject to certain conditions.
Foreign dividends, foreign branch profits, and foreign service fee income received in Singapore may be exempt from tax if they fulfil certain conditions.