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.
|Dividends (1)||Interest (2)||Royalties (2)|
|Non-resident corporations and individuals:|
|Austria||0||5 (3b, d)||5|
|Belgium||0||5 (3b, d)||3/5 (4b)|
|Brunei||0||5/10 (3a, b)||10|
|Cambodia (5d)||0||10 (3b)||10|
|China, People’s Republic of||0||7/10 (3a, b)||6/10 (4b)|
|Cyprus||0||7/10 (3a, b)||10|
|Czech Republic||0||0||0/5/10 (4b, 4c)|
|Ecuador||0||10 (3a, b)||10|
|Fiji Islands, Republic of||0||10 (3b)||10|
|France||0||0/10 (3b, k)||0 (4a)|
|Hong Kong (5c)||0||15||10|
|Hungary||0||5 (3b, d)||5|
|Indonesia||0||10 (3b, e)||10|
|Isle of Man||0||12 (3b)||8|
|Korea, Republic of||0||10 (3b)||10|
|Lao People’s Democratic Republic||0||5 (3b)||5|
|Malaysia||0||10 (3b, f)||8|
|Malta||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||0||10 (3b)||0 (4a)|
|New Zealand||0||10 (3b)||5|
|Pakistan||0||12.5 (3b)||10 (4a)|
|Panama||0||5 (3b, d)||5|
|Papua New Guinea||0||10||10|
|Poland||0||5 (3b)||2/5 (4b)|
|Portugal||0||10 (3b, f)||10|
|San Marino||0||12 (3b)||8|
|South Africa||0||7.5 (3b, j, l)||5|
|Spain||0||5 (3b, d, f, g)||5|
|Sri Lanka (5d)||0||10 (3a, b)||10|
|Sweden||0||10/15 (3b, c)||0 (4a)|
|Switzerland||0||5 (3b, d)||5|
|Thailand||0||10/15 (3a, b, h)||5/8/10 (4d)|
|Turkey||0||7.5/10 (3a, b)||10|
|United Arab Emirates||0||0||5|
|United Kingdom||0||5 (3a, b, i)||8|
|United States (5c)||0||15||10|
|Uruguay (5d)||0||10 (3b, d, j, k)||5/10 (4e)|
|Vietnam||0||10 (3b)||5/10 (4f)|
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.
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