Personal and business taxation in Singapore

Documentary position as at 26 September 2026. The reference points below distinguish the year in which income is derived from the Singapore year of assessment (Year of Assessment, “YA”): income for 2025 is taxed for YA 2026. Amounts are expressed in Singapore dollars (S$) unless stated otherwise.

1. Identifying the year of assessment, the taxpayer and the source of income

1. Singapore applies a territorial income tax: section 10(1) of the Income Tax Act 1947 (ITA) charges income accruing in or derived from Singapore, as well as foreign-sourced income received in Singapore. The preliminary question is therefore not only one of residence, but also one of the source of the income and, for foreign income, of its receipt in Singapore. S02

2. Tax is assessed on a preceding-year basis. For an individual, YA 2026 covers income derived from 1 January to 31 December 2025. For a company, the tax authority (IRAS) states that the income of the financial year ending in a given year is taxed for the following YA. A rate or rebate must therefore always be linked to a specific YA, and not to the calendar year in which the income is derived. S11S25

3. The ITA distinguishes several categories of taxpayer: resident individuals, taxed according to the scale in the Second Schedule; non-resident individuals; companies and bodies of persons; trustees and executors. Section 42 refers to the scale for individuals, and section 43 sets, among other things, the rate for companies and the rate for non-resident individuals. The taxpayer’s status therefore determines both the rate and the entitlement to personal reliefs. S01S05S06

4. The tax landscape is not limited to income tax: GST, stamp duties (including ABSD on residential property), the annual property tax and, for large groups, the Pillar Two top-up taxes are governed by separate legislation. This factsheet presents them separately, without claiming to cover sectoral regimes and individual incentives exhaustively. S26S29S32S38

2. Individual residence, arrival and departure

5. Under the statutory definition in section 2 of the ITA, a resident individual is one who, in the year preceding the YA, resides in Singapore except for such temporary absences as may be reasonable and not inconsistent with that status. The definition includes a person who is physically present, or who exercises an employment other than as a company director, in Singapore for 183 days or more during that preceding year. S01

6. IRAS sets out its administrative reading of this test. A citizen or permanent resident (SPR) who normally resides in Singapore is resident, except for temporary absences. A foreigner is resident if he or she stayed or worked in Singapore for at least 183 days in the preceding calendar year; a stay below that threshold leads, in principle, to non-resident status. S11

7. Two administrative concessions supplement the rule. The first treats as resident, for all three years, a foreigner who stays or works in Singapore continuously over three consecutive years, even if the first and third years each count fewer than 183 days. The second concerns employment exercised over a continuous period straddling two calendar years, where the total period of stay, including presence immediately before and after the employment, is at least 183 days; it applies to foreign employees who entered Singapore on or after 1 January 2007 and excludes company directors, public entertainers and “professionals”. S11

8. In counting days of employment, IRAS includes weekends and public holidays, as well as temporary or employment-related absences, such as overseas leave or business trips. The authority also states that a foreigner holding a work pass valid for at least one year is treated as resident, subject to a review of his or her residence at the departure procedure (tax clearance). S11

9. A tax resident is taxed on Singapore-sourced income, may deduct expenses, donations and personal reliefs, and is subject to a progressive scale from 0% to 24%. IRAS states that his or her foreign-sourced income received in Singapore is exempt, except where it is received through a Singapore partnership. S11S13

10. No exit tax on individuals’ unrealised gains was identified in the legislation and official pages consulted. Departure mainly gives rise to reporting obligations: where an employee who is not a Singapore citizen (a foreigner or an SPR) ceases employment, is posted overseas or plans to leave Singapore for more than three months, the employer must in principle file Form IR21 and withhold the sums due to the employee until tax clearance is given. S18)

11. Dual residence under French and Singapore law is resolved by article 4 of the France–Singapore treaty of 15 January 2015. The tests are successive: permanent home, centre of vital interests, habitual abode, then agreement between the competent authorities. Unlike many treaties, the text does not bring in nationality before the mutual agreement procedure. S43

3. Income tax for residents: scale and foreign income

12. A resident’s chargeable income is determined after deducting allowable expenses, donations and personal reliefs. It is then subject to the progressive scale in the Second Schedule to the ITA, to which section 42 refers. IRAS publishes the scale applicable from YA 2024, summarised in the following table. S06S11S12

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Chargeable income band (YA 2024 onwards)Marginal rateSources
Up to S$20,0000%S12
S$20,000 to S$30,0002%S12
S$30,000 to S$40,0003.5%S12
S$40,000 to S$80,0007%S12
S$80,000 to S$120,00011.5%S12
S$120,000 to S$160,00015%S12
S$160,000 to S$200,00018%S12
S$200,000 to S$240,00019%S12
S$240,000 to S$280,00019.5%S12
S$280,000 to S$320,00020%S12
S$320,000 to S$500,00022%S12
S$500,000 to S$1,000,00023%S12
Above S$1,000,00024%S12

13. According to the IRAS table, gross tax amounts to S$199,150 on chargeable income of S$1,000,000, each additional dollar being taxed at 24%. Before YA 2024, the top band stopped at 22% above S$320,000. A calculation relating to income earlier than 2023 must therefore use the former scale. S12

14. A personal income tax rebate was granted to residents for YA 2024 (50% of tax payable, capped at S$200) and YA 2025 (60%, capped at S$200). The IRAS page on this rebate, updated on 11 August 2026, does not mention a rebate for YA 2026; the rebate can neither be carried forward nor refunded where the tax payable is nil. S12S15

15. Receipt of foreign income is defined by section 10(25) of the ITA: amounts remitted to, transmitted or brought into Singapore, amounts applied in or towards satisfaction of a debt incurred in respect of a trade or business carried on in Singapore, and amounts applied to purchase movable property brought into Singapore are deemed received in Singapore. This definition applies even if the source of the income has ceased. S02

16. Section 13(7A) exempts foreign-sourced income received in Singapore by a non-resident individual, as well as such income received on or after 1 January 2004 by a resident individual where the Comptroller is satisfied that the exemption is beneficial to him or her. The exemption does not cover income received through a Singapore partnership. S03

17. The exemption for foreign income does not extend to income which, although received outside Singapore, is in reality Singapore-sourced. IRAS cites, in particular, overseas employment that is incidental to a Singapore employment, overseas business activity incidental to a business carried on in Singapore, work in Singapore for a foreign employer and overseas employment on behalf of the Singapore Government. The characterisation of the place where the activity is exercised therefore prevails over the place of payment. S13

18. Dividends paid by a Singapore-resident company under the so-called “one-tier” system are in principle not taxable in the hands of the shareholder, the tax paid by the company being final; IRAS makes an exception for co-operatives. Foreign dividends received by a resident individual are not taxable, except where received through a Singapore partnership. S19

19. Gains from the sale of real property, shares or financial instruments are, according to IRAS, generally not taxable for an individual where they are capital gains. Property gains may become taxable where there is a property trading activity: to characterise such property trading, the authority examines the frequency of transactions, the reasons for the purchase and sale, the financial ability to hold the property over the long term and the holding period. S20

20. A resident whose income taxable in Singapore has also been taxed abroad may claim a foreign tax credit. IRAS makes this credit conditional on residence for the relevant year, on foreign tax having been paid or being payable on the same income and on that income being taxable in Singapore; the credit is limited to the lower of the foreign tax and the Singapore tax attributable to the net income. S16

4. Special regimes: the closed NOR scheme and residual concessions

21. The Not Ordinarily Resident (NOR) scheme is closed. IRAS states that the last NOR statuses granted cover YA 2020 to 2024 and that beneficiaries retain the concessions until their status expires, provided they continue to meet the conditions. For a new arrival in 2026, this scheme is therefore not available. S14-scheme)

22. The main NOR concession allowed the portion of Singapore employment income corresponding to days spent outside Singapore for business reasons not to be taxed. It required at least 90 days of business absence and Singapore employment income of at least S$160,000, with a minimum tax equal to 10% of total employment income; director’s fees and Singapore tax borne by the employer could not be apportioned. S14-scheme)

23. A second concession exempted, subject to a cap, employer contributions to a non-mandatory overseas pension or social security scheme, for an employee who was neither a citizen nor an SPR and who earned at least S$160,000, provided that the employer did not deduct the contribution. These conditions are recalled only for earlier cases or statuses still running for the YAs covered. S14-scheme)

24. No inbound expatriate regime open in 2026 comparable to a lump-sum regime was identified in the official pages consulted. Singapore’s tax attraction for an individual rests on the general rules: a scale capped at 24%, the exemption of foreign income received other than through a partnership and the absence of tax on non-speculative capital gains. Individual and sectoral incentives not examined here must be checked case by case. S03S12S20

5. Non-residents and withholding tax

25. A non-resident is taxed on Singapore-sourced income and may deduct expenses and donations, but is not entitled to personal reliefs. His or her employment income is taxed at the higher of two amounts: a flat 15% or the tax calculated under the progressive resident scale. S11S12

26. A non-resident’s other income, in particular director’s fees, consultancy fees, pensions and rental income, is in principle taxed at 24%. Section 43(1)(b) of the ITA sets this rate from YA 2024, compared with 22% up to YA 2023. Income subject to reduced withholding tax rates is governed by its own rules; for a non-resident professional, the withholding is 15% of the gross amount or, by election, the non-resident rate on the net income (§30). S05S11S12S21

27. Employment exercised in Singapore for 60 days or less in the year by a non-resident is exempt. This exemption does not apply to company directors, public entertainers or “professionals”, a category which includes, in particular, foreign experts, speakers, consultants, trainers and coaches. S11

28. Section 45 of the ITA requires a payer of interest to a person not known to the payer to be resident to withhold tax, in principle at 24% for an individual and 17% for any other person, and to pay it over to the Comptroller. Section 45A extends this mechanism to income referred to in section 12(6) and (7), in particular royalties, management fees and payments for services. S07S08

29. Section 12(6) deems to be Singapore-sourced interest, commission and fees in connection with a loan that are borne directly or indirectly by a resident or a permanent establishment in Singapore (except where they relate to a business carried on outside Singapore through a permanent establishment outside Singapore or to immovable property situated outside Singapore), or that are deductible against Singapore-sourced income, as well as income from loans whose funds are brought into or used in Singapore. This source rule determines whether withholding applies. S09

30. IRAS publishes the rates applicable by type of payment. For interest, royalties and rent of movable property, the reduced rates shown below apply where the income is derived from operations carried on outside Singapore; they are levied on the gross amount and constitute a final tax. Where the operations are carried on in Singapore, the corporate income tax rate or the 24% rate for an individual applies. S21

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Payment to a non-residentRate stated by IRASSources
Interest, commission and fees in connection with a loan15%S21
Royalties for the use of movable property, including intellectual property (excluding royalties of authors, composers and choreographers: 24% on the lower of the net amount or 10% of the gross amount up to YA 2026, concession withdrawn in stages from YA 2027)10%S21
Scientific, technical, industrial or commercial information and know-how10%S21
Rent of movable property15%S21
Technical assistance, services and management fees paid to a non-resident companyPrevailing corporate income tax rateS21
Remuneration of a non-resident director24%S21
Non-resident independent professional15% of gross or non-resident rate on netS21
Non-resident public entertainer15% of grossS21

31. For services rendered by a non-resident company, the withholding follows the corporate income tax rate for the year in which the services are performed. The company may request to be taxed on its net income by submitting its audited accounts and a tax computation; any excess withholding is then refunded to it. The IRAS list does not cover dividends, and “one-tier” dividends are not taxable in the hands of the shareholder. S19S21

32. Domestic rates may be reduced by treaty. To benefit, a non-resident must in principle establish to IRAS his or her residence in the partner State by means of a certificate of residence certified by that State’s tax authority. The conditions specific to each treaty, including the anti-abuse clause where there is one, must be checked. S17)S24

6. Companies: residence, tax base, rates and foreign gains

33. A company is resident in Singapore where the control and management of its business is exercised there. IRAS defines such control as the making of strategic decisions and generally looks to the place where board meetings are held; it also examines where the directors are located, the decisions taken by the local director and the presence of key employees. The place of incorporation is not decisive on its own. S01S23

34. For a virtual meeting, IRAS generally considers that strategic decisions are taken in Singapore if at least 50% of the authorised directors are physically present there, or if the chairman of the board is present there. An investment holding company owned by foreigners and deriving passive or foreign income is in principle not regarded as resident, save in particular circumstances. S23

35. Section 43(1)(a) of the ITA sets the corporate income tax rate at 17%, applicable to resident and non-resident companies. For YA 2026, the tax rebate announced in Budget 2026 at 40% was subsequently raised to 50% of tax payable, subject to a cap of S$40,000. Active companies that made CPF contributions for at least one local employee (a citizen or permanent resident, excluding shareholder-directors) in 2025 receive a cash grant of S$2,000, deducted from the capped rebate; if the computed rebate does not exceed S$2,000, a company eligible for the grant receives no rebate. S05S22

36. The rebate is computed on the tax after set-offs such as the foreign tax credit, but before tax deducted at source. It also applies to income taxed at a concessionary rate, but not to income subject to final withholding tax. The company must not deduct it in its returns: IRAS grants it on assessment. S22

37. The partial tax exemption under section 43 of the ITA has, since YA 2020, exempted 75% of the first S$10,000 of chargeable income taxable at the normal rate and 50% of the next S$190,000, i.e. S$102,500 at most. It is available to all companies that do not benefit from the start-up tax exemption. S22

38. The exemption for new companies covers, for the first three consecutive YAs, 75% of the first S$100,000 and 50% of the next S$100,000, i.e. S$125,000 at most per YA. It excludes companies whose principal activity is that of investment holding, as well as those undertaking property development for sale, for investment or for both. The company must be incorporated and resident in Singapore, and its share capital must be held directly by no more than 20 shareholders, all of whom are individuals or at least one of whom is an individual holding 10% of the ordinary shares. S22

39. A company files each year an estimate of its chargeable income (Estimated Chargeable Income, ECI) and an income tax return (Form C-S, Form C-S (Lite) or Form C). IRAS states that the ECI must be filed within three months of the end of the financial year, including for the first financial year ending in the year of incorporation, unless waived; the income tax return is due on 30 November each year. S25

40. A company’s foreign income is in principle taxable on its receipt in Singapore; if it arises from a business carried on in Singapore, it is taxable as soon as it accrues, whether or not it is remitted. Sections 13(8) and 13(9) of the ITA exempt foreign dividends, foreign branch profits and foreign-sourced service income received by a resident, if three conditions are met. S03S24

41. The three conditions are as follows: the income was subject, in the jurisdiction from which it is received, to a tax of a similar character to income tax or to a qualified domestic top-up tax; the highest rate of tax on profits in that jurisdiction is at least 15% at the time of receipt in Singapore; and the Comptroller is satisfied that the exemption is beneficial. The current wording of the first two conditions results from Act 36 of 2024, in force on 20 March 2025. S03S24

42. Section 10L of the ITA taxes, for disposals occurring on or after 1 January 2024, gains from the disposal of an asset situated outside Singapore by an entity of a “relevant” group, where those gains are received in Singapore and would not otherwise be taxable or would be exempt. A group is relevant if its entities are not all established in a single jurisdiction or if one of them has a place of business in more than one jurisdiction. S04

43. Section 10L excludes, among others, prescribed financial institutions, certain activities benefiting from incentives and “excluded entities”. A pure equity-holding entity is excluded if it complies with its filing obligations, if its operations are managed and performed in Singapore and if it has adequate human resources and premises there. Any other entity must both have its operations managed and performed there and demonstrate adequate economic substance there, assessed in particular by reference to its employees, their qualifications, its expenditure and where key decisions are made. S04

44. For section 10L, the location of assets follows its own rules. Shares in a company are in principle situated in the country of incorporation, but registered shares and securities are situated where the register is kept (the principal register where there is more than one), subject to securities issued by public authorities; a debt is situated where the creditor resides; immovable property where it is located. Receipt follows the same logic as section 10(25), and the provision allows the deduction of acquisition and disposal expenses and of certain losses on other foreign assets. S04

45. Section 13W exempts gains from the disposal of shares in a company made by a company that has held at least 20% of the ordinary shares for a continuous period of at least 24 months. The provision was amended by Act 25 of 2025: the former provision covers disposals up to 31 December 2025, and two new subsections (1A) and (1B) cover, for disposals on or after 1 January 2026, ordinary or preference shares, the first according to a 20% shareholding or value test, the second according to its own 24-month holding conditions. The other conditions and exclusions of the provision have not been reconstructed here. S10

46. The Pillar Two rules are implemented by the Multinational Enterprise (Minimum Tax) Act 2024 (Act 36 of 2024). The minimum rate is set at 15%. The Act applies, for financial years beginning on or after 1 January 2025, to groups whose consolidated revenue reached EUR 750 million in at least two of the four preceding financial years. S26S27-rules-and-domestic-top-up-tax-(dtt))

47. Singapore levies two taxes: the Multinational Enterprise Top-up Tax (MTT), which corresponds to the income inclusion rule for low-taxed profits of entities located outside Singapore, and the Domestic Top-up Tax (DTT), which targets low-taxed profits of entities located in Singapore. IRAS states that the undertaxed profits rule (UTPR) is not being implemented at this stage. S27-rules-and-domestic-top-up-tax-(dtt))S28

48. Groups within scope must register once, within six months of the end of the first financial year subject to the Act; for a financial year ending on 31 December 2025, the stated deadline is 30 June 2026. IRAS also announces the implementation of the “Side-by-Side” package of 5 January 2026: the legislative amendments are planned by the end of 2026, subject to parliamentary approval, and the simplified effective tax rate safe harbour targets financial years beginning on or after 31 December 2026. S27-rules-and-domestic-top-up-tax-(dtt))S28

7. GST: rates, registration and overseas vendors

49. Section 16 of the Goods and Services Tax Act 1993 has set the GST rate at 9% since 1 January 2024, after 8% in 2023 and 7% from 1 July 2007 to 31 December 2022. The tax is charged on supplies of goods and services, including supplies subject to reverse charge, and on imports of goods. S29S30/basics-of-gst/current-gst-rates)

50. A GST-registered person must charge GST at 9% on its sales of goods and services in Singapore, except for zero-rated or exempt supplies. Exports of goods and international services are in principle zero-rated; exempt supplies are not zero-rated, except, according to IRAS, those that qualify as international services, such as financial services provided to persons established overseas. S30/basics-of-gst/current-gst-rates)S31/gst-registration-deregistration/do-i-need-to-register-for-gst)

51. Registration is compulsory where taxable turnover exceeded S$1 million in the past calendar year (retrospective view), or where it is reasonably expected to exceed that threshold in the next twelve months (prospective view), on the basis of supporting evidence such as signed contracts. Taxable turnover includes standard-rated and zero-rated supplies, but excludes exempt supplies, including those that qualify as international services and are zero-rated, out-of-scope supplies and sales of capital assets. S31/gst-registration-deregistration/do-i-need-to-register-for-gst)

52. Under the retrospective view, the application must be filed between 1 and 30 January of the following year, registration taking effect on 1 March. Under the prospective view, the application must be made within 30 days of the forecast; for a liability arising on or after 1 July 2025, registration takes effect two months after the date of the forecast. S31/gst-registration-deregistration/do-i-need-to-register-for-gst)

53. Separate reverse charge and overseas vendor registration regimes may also require registration. IRAS also brings the supply of imported low-value goods into taxable turnover from 1 January 2023. The thresholds and conditions of these regimes have not been reconstructed in this factsheet. S31/gst-registration-deregistration/do-i-need-to-register-for-gst)

8. Real estate: stamp duties, ABSD and property tax

54. Stamp duties under the Stamp Duties Act 1929 are charged on instruments relating to immovable property situated in Singapore and to shares. The purchase of a property gives rise to Buyer’s Stamp Duty (BSD), calculated on the higher of the price or the market value. Since 15 February 2023, the scale has been 1% on the first S$180,000, 2% on the next S$180,000, 3% on S$640,000, 4% on S$500,000, 5% on S$1,500,000, then 6% on the remainder for residential property; non-residential property is capped at 5%. S32S33S35)

55. BSD is not limited to sales: IRAS also covers acquisition by way of gift, including by a declaration of trust involving a change in beneficial ownership, distribution in specie on a liquidation and certain distributions of an estate that do not follow the will or the rules of intestate succession. S35)

56. Additional Buyer’s Stamp Duty (ABSD) is payable in addition to BSD on the acquisition of residential property. It depends on the buyer’s profile at the date of purchase: individual or entity, citizen, SPR or foreigner, and number of residential properties already owned, including those held on trust. The rates applicable to instruments executed on or after 27 April 2023 are set out below. S33S34)

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Buyer profile (residential property)ABSD since 27 April 2023Sources
Citizen, first propertyNot applicableS33
Citizen, second property20%S33
Citizen, third and subsequent property30%S33
Permanent resident, first property5%S33
Permanent resident, second property30%S33
Permanent resident, third and subsequent property35%S33
Foreigner, any property60%S33
Entity, any property65%S33
Trustee (save for exceptions), any property65%S33S34)
Housing developer35% remittable subject to conditions, plus 5% non-remittableS33

57. Since 9 May 2022, the transfer of residential property into a trust has borne ABSD at the entity rate, currently 65%, payable upfront; a remission by way of refund may be claimed within six months where the property is held for identifiable individual beneficiaries, subject to conditions. In an FAQ concerning a permanent resident of United States nationality, IRAS states that, under the free trade agreement, such a buyer is accorded the same treatment as a Singapore citizen; the pages consulted do not mention such treatment for French nationals. S33S34)

58. Seller’s Stamp Duty (SSD) is charged on the resale, during the holding period, of residential property acquired on or after 20 February 2010. For property purchased on or after 4 July 2025, the rate is 16% on a resale within one year, 12% between one and two years, 8% between two and three years, 4% between three and four years, and nil thereafter. For a purchase between 11 March 2017 and 3 July 2025, the period is three years, with rates of 12%, 8% and 4%. S33S36-for-residential-property)

59. Whether a property is residential is determined, for a unit in a building, by the permitted use at the date of acquisition or disposal and, for vacant land or an entire building, by the Master Plan zoning. A mixed-use property is apportioned between its components. The acquisition of shares in a company whose assets consist primarily of residential property may also trigger additional duties (ACDB and ACDS) based on the value of the underlying properties. S33S37

60. Property tax is an annual tax levied on the annual value, defined by the Property Tax Act 1960 as the gross rent at which the property could reasonably be expected to be let from year to year. For an owner-occupied residence, the progressive scale in force since 1 January 2025 ranges from 0% on the first S$12,000 of annual value to 32% above S$140,000. S38S39S40

61. A residential property that is not owner-occupied, in particular one that is let, has been subject since 1 January 2024, except for properties on an exclusion list published by IRAS, to a scale of 12% on the first S$30,000, 20% on the next S$15,000, 28% on the next S$15,000 and 36% above S$60,000. Other properties, commercial and industrial, are taxed at 10% of the annual value. S39

62. For an individual, rental income from a property situated in Singapore is Singapore-sourced income: a resident includes it in chargeable income taxed at the rate scale, and a non-resident is in principle taxed at 24%. Transfer duties, ABSD, property tax and income tax are distinct levies that apply cumulatively. S02S12

9. Wealth: no wealth tax and indirect taxation of holdings

63. No annual tax on the net wealth of individuals was identified in the legislation and official pages consulted. The holding of assets is nevertheless reached indirectly: annual property tax on real estate, stamp duties on acquisitions and disposals, and tax on Singapore-sourced income. S32S38S39

64. The transfer or contribution of assets to a structure must be examined from the standpoint of stamp duties. A transfer of residential property to a company or a trust bears ABSD at the entity or trustee rate, and a transfer of shares bears, in principle, duty of 0.2% of the price or value of the shares. S33S34)

65. The holding of foreign assets by a resident individual does not in itself give rise to tax in Singapore on the income derived from them, as long as that income is not received through a Singapore partnership or connected with a Singapore business. This rule has no effect on the taxation of the same assets or income in the State where they are situated. S03S13

66. Singapore has exchanged financial account information with its partners under the Common Reporting Standard (CRS) since September 2018. IRAS states that the country has committed to implementing the amendments to the standard adopted on 8 June 2023, with first exchanges under the amended standard expected in 2028. S47)

10. Inheritances and gifts

67. The Estate Duty Act 1929 applies only to persons who died before 15 February 2008. IRAS confirms that estate duty was abolished for deaths occurring on or after that date. The valuation and exemption rules still published, such as the S$9 million exemption for residential properties or the treatment of CPF accounts, concern only earlier estates. S41S42

68. No separate gift tax was identified in the official sources consulted. A gift of immovable property nevertheless remains an instrument subject to ad valorem stamp duties, including ABSD on residential property according to the recipient’s profile. S35)S34)

69. An estate opened in Singapore does not remove the need for a French-law analysis: the France–Singapore treaty of 15 January 2015 covers only taxes on income. French inheritance and gift taxes applicable to a deceased person, an heir or assets connected with France must be analysed under French domestic law, outside the scope of this factsheet. S43S44

70. Income of an estate or a trust remains subject to income tax. Section 43(1)(c) of the ITA sets the rate applicable to trustees and executors at 17%, and section 43(2) allows the part of the trustee’s income corresponding to a beneficiary’s entitlement to be taxed at a lower rate, or not to be taxed, under the conditions laid down. S05

11. France–Singapore treaty and international obligations

71. The treaty between France and Singapore for the avoidance of double taxation and the prevention of fiscal evasion and fraud with respect to taxes on income was signed on 15 January 2015 and published by Decree No. 2016-896 of 30 June 2016. It entered into force on 1 June 2016 and replaced the treaty of 9 September 1974, as amended by the protocol of 13 November 2009. It applies in France to income for 2017 and, in Singapore, to YAs beginning on or after 1 January 2018 for tax not withheld at source. S44

72. The treaty is modified by the BEPS Multilateral Convention (MLI), which entered into force on 1 January 2019 for France and on 1 April 2019 for Singapore. The consolidated version published by the DGFiP inserts, in particular in article 28, a principal purpose test: a benefit is denied where it is reasonable to conclude that obtaining it was one of the principal purposes of an arrangement, unless it is in accordance with the object and purpose of the treaty. This consolidated version is not an authentic text. S43

73. Dividends paid by a company resident in one State to a resident of the other State may be taxed in the State of the distributing company, up to a limit of 5% if the beneficial owner is a company holding directly or indirectly at least 10% of the capital, and 15% in all other cases. As Singapore does not levy withholding tax on “one-tier” dividends, the limit is relevant mainly for French-source dividends. S19S21S43

74. Interest is taxable in the source State up to a limit of 10%; it is, however, taxable only in the State of residence of the beneficial owner in the cases covered by article 11(3), in particular where it is paid by an enterprise of one State to an enterprise of the other State. Royalties are in principle taxable only in the State of residence of the beneficial owner; however, royalties relating to certain copyrights in literary or artistic works and to information concerning commercial experience remain taxable in the source State in accordance with its laws. S43

75. Gains from immovable property are taxable in the State where the property is situated, as are gains from the disposal of shares in an entity whose assets derive more than 50% of their value from immovable property situated in that State, immovable property used in the company’s own business not being taken into account. Gains from the disposal of movable property forming part of the business property of a permanent establishment are taxable in the State where it is situated, and gains from ships and aircraft operated in international traffic in the State in which the place of effective management of the enterprise is situated; all other gains are taxable only in the State of residence of the alienator. Salaries follow the 183-day rule over any twelve-month period, and directors’ fees are taxable in the State of the company. S43

76. Article 22 limits the benefits granted in France where Singapore taxes French-source income only by reference to the amount remitted to or received in Singapore: the French exemption or reduction of tax then applies only to the portion remitted to or received in Singapore. The limitation does not cover income of the States and of the public bodies referred to in article 11(3) a), and it does not apply where Singapore exempts the French-source income to eliminate double taxation under article 23. S43

77. In Singapore, double taxation is eliminated by exemption if the domestic conditions for exempting foreign income are met, and failing that by tax credit; dividends paid by a French company to a Singapore company holding directly at least 10% of the capital are exempt. In France, income taxable in Singapore is taken into account, unless exempt from corporate income tax under 2 b) (dividends from direct holdings of at least 10%, remitted permanent establishment profits) or under domestic law, with a tax credit. For the income listed in (ii), in particular permanent establishment profits subject to corporate income tax, dividends, interest, royalties under article 12(3), gains from immovable property and directors’ fees, this credit is equal to the tax paid in Singapore, up to the amount of the corresponding French tax; for other income, it is equal to the corresponding French tax, provided that the beneficiary is subject to Singapore tax in respect of that income. S43

78. Singapore states that it has concluded treaties, limited treaties and exchange of information arrangements with around a hundred jurisdictions. For Singapore residents, proof of residence takes the form of a certificate of residence issued by IRAS; for residents of partner States, of a certificate issued by their own tax authority. S24S45S46_4th-edition.pdf?sfvrsn=39d9d572_6)

12. Illustrative cases and limits of application

79. Case 1 — a French executive moves to Singapore on 1 March 2025 with a three-year local contract. He or she stays more than 183 days in 2025 and becomes resident for YA 2026: his or her Singapore employment income is taxed at the rate scale; his or her French-source dividends are not taxed in Singapore if they are not received through a Singapore partnership, and they remain taxable in France up to the 15% limit, without article 22 appearing to restrict that ceiling: that clause presupposes that Singapore taxes the income by reference to the amount remitted or received, whereas section 13(7A) exempts foreign income received by a resident individual, subject to the Comptroller being satisfied. His or her French residence must in addition be resolved under article 4 if French law also regards him or her as resident. S03S11S13S43

80. Case 2 — a non-resident consultant works for 40 days in Singapore for a local client. The exemption for employment of 60 days or less does not apply to “professionals”; the client must in principle withhold 15% of the gross amount, the consultant being able to elect to be taxed at the non-resident rate on net income. The treaty may alter this outcome depending on the characterisation of the income and on the existence of a permanent establishment within the meaning of article 5, including a services permanent establishment beyond 365 days within any fifteen-month period, independent professions falling under article 7; this point must be checked. S11S21S43

81. Case 3 — a Singapore holding company of an international group receives a dividend from a French subsidiary in which it directly holds 30% and disposes of shares in a foreign company. The dividend is exempt under article 23 of the treaty; the disposal gain, if remitted to Singapore, falls within section 10L, which applies even to gains otherwise exempt under the ITA, including, subject to the legislation, under section 13W; it falls outside that section only if the holding company is an “excluded entity” with substance in Singapore or falls within another exclusion provided for in subsections (6) to (8) of section 10L. If the group reaches EUR 750 million in revenue, the DTT and the MTT must also be examined. S04S10S26S43

82. Case 4 — a French expatriate without permanent resident status buys an apartment for S$2 million to live in. He or she bears BSD under the residential scale and, in the absence of any identified treaty-based treatment for French nationals, the 60% ABSD applicable to foreigners. A resale within four years of a purchase made on or after 4 July 2025 would trigger SSD; the annual property tax falls under the owner-occupier scale if he or she meets its conditions, in particular personal ownership and occupation of the property by an individual or a married couple, only one residence per couple being eligible. S33S34)S36-for-residential-property)S39S40

83. Limits of application: this factsheet does not reconstruct all personal reliefs, CPF contributions, sectoral incentives (including fund and family office regimes), or the detail of transfer pricing rules, GST regimes for overseas vendors and Pillar Two following the amendments announced for the end of 2026. The French consequences of departure, in particular exit tax and inheritance tax, are not analysed. Each rule must be checked against the legislation and official pages as at the date of the transaction. S22S27-rules-and-domestic-top-up-tax-(dtt))S31/gst-registration-deregistration/do-i-need-to-register-for-gst)S43

Sources