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 which are not carrying on any business in Singapore and which have no PE in Singapore. Technical assistance and management fees for services rendered in Singapore by non-resident companies 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% (or 24% from year of assessment 2024) on net income if this results in a lower tax cost.
Ship charter fee payments are not subject to WHT.
The WHT rates are shown in the following table.
|Dividends (1)||Interest (2)||Royalties (2)|
|Non-resident corporations and individuals:|
|Albania (6)||0||5 (3b)||5|
|Armenia||0||5 (3b, k)||5|
|Australia (6)||0||10||10 (4a)|
|Austria (6)||0||5 (3b, d)||5|
|Bahrain (6)||0||5 (3b)||5|
|Barbados (6)||0||12 (3b)||8|
|Belgium (6)||0||5 (3b, d)||3/5 (4b)|
|Brazil||0||10/15 (3b, p, q)||10|
|Brunei||0||5/10 (3a, b)||10|
|Canada (6)||0||15 (3e)||10|
|China, People’s Republic of (6)||0||7/10 (3a, b)||6/10 (4b)|
|Cyprus (6)||0||7/10 (3a, b)||10|
|Czech Republic (6)||0||0||0/5/10 (4b, 4c)|
|Denmark (6)||0||10 (3b)||10|
|Ecuador||0||10 (3a, b)||10|
|Egypt (6)||0||15 (3b)||10|
|Fiji Islands, Republic of||0||10 (3b)||10|
|Finland (6)||0||5 (3b)||5|
|France (6)||0||10 (3b, j, k, o)||0 (4a)|
|Greece (5d)||0||7.5 (3a, b)||7.5|
|Guernsey (6)||0||12 (3b)||8|
|Hong Kong (5c)||0||15||10|
|Hungary (6)||0||5 (3b, d)||5|
|India (6)||0||10/15 (3a)||10|
|Indonesia (6)||0||10 (3b)||8/10 (4h)|
|Ireland (6)||0||5 (3b)||5|
|Isle of Man (6)||0||12 (3b)||8|
|Israel (6)||0||7 (3b)||5|
|Japan (6)||0||10 (3b)||10|
|Jersey (6)||0||12 (3b)||8|
|Jordan||0||5 (3b, p)||5|
|Kazakhstan (6)||0||10 (3b)||10|
|Korea, Republic of||0||10 (3b, n)||5|
|Lao People’s Democratic Republic||0||5 (3b)||5|
|Latvia (6)||0||10 (3m)||5|
|Liechtenstein (6)||0||12 (3b)||8|
|Lithuania (6)||0||10 (3b)||7.5|
|Malaysia (6)||0||10 (3b, f)||8|
|Malta (6)||0||7/10 (3a, b)||10|
|Mexico||0||5/15 (3a, b)||10|
|Mongolia||0||5/10 (3a, b)||5|
|Myanmar||0||8/10 (3a, b)||10|
|Netherlands (6)||0||10 (3b)||0 (4a)|
|New Zealand (6)||0||10 (3b)||5|
|Oman (6)||0||7 (3b)||8|
|Pakistan (6)||0||12.5 (3b)||10 (4a)|
|Panama (6)||0||5 (3b, d)||5|
|Papua New Guinea||0||10||10|
|Poland (6)||0||5 (3b)||2/5 (4b)|
|Portugal (6)||0||10 (3b, f)||10|
|Qatar (6)||0||5 (3b)||10|
|Russian Federation (6)||0||0||5|
|San Marino (6)||0||12 (3b)||8|
|Saudi Arabia (6)||0||5||8|
|Serbia||0||10 (3b, p)||5/10 (4f)|
|Seychelles (6)||0||12 (3b)||8|
|Slovak Republic (6)||0||0||10|
|Slovenia (6)||0||5 (3b)||5|
|South Africa||0||7.5 (3b, j, l)||5|
|Spain (6)||0||5 (3b, d, f, g)||5|
|Sri Lanka||0||10 (3a, b)||10|
|Sweden||0||10/15 (3b, c)||0 (4a)|
|Switzerland||0||5 (3b, d)||5|
|Thailand (6)||0||10/15 (3a, b, h)||5/8/10 (4d)|
|Tunisia||0||0/5/10 (3a, b)||5/10 (4e)|
|Turkey||0||7.5/10 (3a, b)||10|
|Turkmenistan||0||10 (3b, j, k)||10|
|Ukraine (6)||0||10 (3b)||7.5|
|United Arab Emirates (6)||0||0||5|
|United Kingdom (6)||0||5 (3a, b, i)||8|
|United States (5c)||0||15||10|
|Uruguay (6)||0||10 (3b, d, j, k)||5/10 (4f)|
|Vietnam||0||10 (3b)||5/10 (4g)|
- 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.
- 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.
- Lower rate or exemption if received by a financial institution.
- Exempt if paid to the government.
- Lower rate or exemption if paid by an approved industrial undertaking.
- Exempt if paid by a bank and received by a bank.
- Exempt if paid to a bank but linked to a government loan agreement or paid to specific financial institutions/banks.
- Exempt if paid in respect of an approved loan or indebtedness.
- Exempt if paid to an approved pension fund.
- 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.
- Exempt if paid by a financial institution.
- Exempt if paid by the government.
- Exempt if paid in respect of a loan that is guaranteed or insured by the government.
- Exempt if paid in respect of any debt instrument listed on a recognised stock exchange.
- Exempt if received by the government or a financial institution, received from and paid by a company (other than a partnership), or paid in respect of a loan, debt-claim, or credit that is guaranteed or insured by the government.
- Exempt if paid in connection with the sale on credit of any industrial, commercial, or scientific equipment, or merchandise.
- Exempt if paid by an enterprise to another enterprise.
- Excludes interest on funds directly connected with the operation of ships or aircraft in international traffic.
- Lower rate if paid to a bank for a loan of at least five years for the financing of equipment or of investment projects.
- Royalties on literary or artistic copyrights, including film royalties, are taxed at the non-treaty rate.
- Lower rate for payments in connection with industrial, commercial, or scientific equipment.
- Royalties on literary, artistic, or scientific work, except computer software, but including film royalties, are exempt.
- 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.
- Lower rate on payments for technical services.
- Lower rate on copyright of literary, artistic, or scientific work, including cinematograph films, or films or tapes used for radio or television broadcasting.
- Lower rate for payments in connection with patents, designs, secret formulas/processes, or industrial, commercial, or scientific equipment/experience.
- Lower rate on payments for industrial, commercial, or scientific equipment, or for information concerning industrial, commercial, or scientific experience.
- Treaty with Bermuda covers only the exchange of information.
- Treaty with Chile covers only international ship operations.
- Treaties with Hong Kong and the United States cover only shipping and air transport activities.
- Treaty applies from 1 January 2023.
- The Multilateral Convention to Implement Tax Treaty Related Measures to Prevent Base Erosion and Profit Shifting (the MLI) was ratified and entered into force for Singapore on 1 April 2019. Amendments made by the MLI to these treaties have taken effect.