Who needs input-tax attribution
The tenth edition dated 30 January 2026 applies to GST-registered businesses making taxable and exempt supplies. Exempt categories include residential property, financial services, investment precious metals and digital payment tokens from 1 January 2020. Input tax means GST on your business purchases/imports. Ordinary documentation and blocked-input conditions still apply; attribution decides which business supplies the expense serves, rather than validating an otherwise ineligible expense. The guide explains classification; the companion partial-exemption guide supplies the detailed recovery/apportionment formulas.
Three classifications after the de minimis test
If the de minimis rule is met, input attributable to exempt supplies can be recovered subject to normal eligibility. Otherwise segregate directly taxable input (fully recoverable), directly exempt input (not recoverable except applicable regulation 33/35 treatment), and residual input serving both categories or the business as a whole (apportioned). Use and retain the Partial Exemption Input Tax Recovery Calculator if helpful; it is not routinely sent to IRAS.
De minimis and regulation 35 are different tests
De minimis requires total exempt supplies to be at or below both an average S$40,000 a month and 5% of total taxable/exempt supplies in the period. Regulation 35 instead tests non-regulation 33 exempt supplies at or below 5% of total taxable/exempt supplies in the longer period; it does not apply the S$40,000 ceiling. For both denominators, exclude received customer-accounting supplies, reverse-charge imported services/LVG and OVR remote services/LVG supplied on behalf of underlying vendors. Do not inflate the taxable denominator with those accounted-for transactions.
Every regulation 33 category
Where regulation 35 is satisfied and the business is not excluded under regulation 34, input on the following exempt supplies is treated as attributable to taxable supplies. First issue is not confined to the original IPO or first debt instrument: the guide includes subsequent new issues by the same issuer. Selling existing shares is a different supply and does not become a first issue.
| Regulation 33 category |
|---|
| Money deposits |
| Currency exchange |
| First issue of debt securities, including subsequent new issues by the issuer |
| First issue of equity securities, including IPO/subsequent new shares |
| Employee loans, advances or credit |
| Assignment of trade receivables |
| Unit trust/business trust unit issues |
| Prescribed hedging activities |
| Bond interest |
| Trade credit |
| Issue/ownership transfer of Islamic debt securities |
| Financing under Islamic debt security arrangements |
Every regulation 34 business exclusion
The regulation 33 recovery provision is unavailable to businesses carrying on, or carrying on a similar business to, the twelve listed classes. The unit-trust entry excludes the specified REIT/business-trust and special-purpose-vehicle cases. Being an investment-related business does not automatically place you in every listed category; compare the actual activity and statutory licensing description.
| Excluded business class |
|---|
| Licensed banks |
| Licensed/deemed-licensed merchant banks |
| MAS Act section 28 approved institutions |
| Life insurers; general/life reinsurers; reinsurance brokers |
| Licensed finance companies |
| Licensed moneylenders or currency traders |
| Payment Services Act cross-border transfer/money-changing licensees |
| Licensed pawnbrokers |
| Debt factors |
| Credit/charge/other payment card companies |
| Unit trusts, excluding the stated REIT/business trust and SPV cases |
| Digital payment token traders |
Direct attribution: cost component or actual input
First examine whether the purchase is a cost component of one supply, such as raw materials included in cost of goods sold. If not shown against sales in the accounts, examine actual use: it must be used to make the supply rather than merely linked to it. Normally it cannot serve a supply already made. It cannot be attributed to a later taxable supply where an exempt supply intervenes, even if the exempt transaction ultimately funds taxable business. Non-business expenditure fails before this classification exercise.
Six introductory illustrations
Commercial-property conveyancing supports taxable leasing even if not booked as lease cost; if used as own office, it is residual. Commercial land later rezoned residential and sold is an exempt land transaction: later dormitory construction services do not change the land input. Annual listing fees two years after an IPO cannot be assigned to that past share issue. IPO professional costs are attributable to the intervening exempt share issue; share-sale brokerage similarly to the exempt sale, even when proceeds fund taxable business. Bond-issue input goes to the exempt bond issue, not the later zero-rated overseas loan funded by proceeds.
Residual input is not reclassified by cost recovery
Costs serving taxable and exempt supplies are residual, including mixed residential/commercial property marketing. Charging those costs back as part of taxable income does not change the original use. Overheads, office rent and utilities serve the whole business and are residual. Dividend-payment costs do not produce a supply but support the business’s return of capital to investors and are treated as residual.
All ten ABC investment-holding-company applications
ABC is a listed investment holding company providing management services, earning property rent and dividends, and making exempt loans/residential leases/share and bond issues. The table preserves every application and important alternative. In the mortgage example borrowing is not ABC itself making an exempt supply, so no intervening exempt supply arises; this differs from issuing shares/bonds. Initial listing and annual maintenance fees likewise have different uses.
| Example | Expense | Attribution |
|---|---|---|
| 1 | Purchase conveyancing for commercial property leased | Taxable direct; full eligible recovery |
| 2 | Mortgage professional fees for that property | Taxable direct; general working-capital/asset loan fees instead residual |
| 3 | Legal agreement lending to local subsidiary | Exempt direct; not recovered in example |
| 4 | Advertising a mixed residential/commercial lease development | Residual; apportion |
| 5 | Overheads, office rent and utilities | Residual; apportion |
| 6 | Initial versus annual SGX listing | Initial: regulation 33 share-issue input; annual: residual |
| 7 | Professional fees issuing shares/bonds to fund management services | Exempt direct; regulation 35 may allow recovery |
| 8 | Administrative costs paying dividends | Residual; apportion |
| 9 | Brokerage buying local investment shares | Future exempt-sale input, not residual merely due to long holding |
| 10 | Legal costs collecting defaulting customer debts | Residual, not directly attributable to past sale |
Reverse-charge implications
Imported services from 2020 and LVG from 2023 can be subject to reverse charge for businesses, or GST groups, not entitled to full input recovery. Imports directly attributable to taxable supplies are generally excluded from reverse charge. However, this exclusion is unavailable to a business on a prescribed fixed input recovery rate or a special formula applied to all input. Use the separate reverse-charge guide for full scope rather than treating a taxable-use assertion as a universal exclusion.
FAQ 1: termination expenses
Liquidation/legal closing costs arise in the course/furtherance of winding up and are generally residual. Full recovery is possible even without current taxable supplies if, before winding up, the business made only taxable supplies, or was not a regulation 34 business and made only taxable plus regulation 33 exempt supplies. A business previously making non-regulation 33 exempt supplies or falling in regulation 34 apportions under its allowed formula. Under the standard formula, no taxable supplies in the expense period means no recovery for that period.
FAQ 1: continuing overheads after cessation
Non-termination expenses are incurred after cessation but not for winding up, such as continuing office rent/utilities; they arise regardless of the decision to liquidate. Apply the ordinary attribution/apportionment rules. For a mixed taxable/exempt business, if no taxable supplies occur in the relevant accounting or longer period, no input can be recovered under the explained treatment. Do not extend the special fully-taxable-business termination concession to every continuing bill.
FAQs 2–4: branches, shares and due diligence
Attribute intra-branch costs to the legal entity’s ultimate external customer supplies, not the internal transfer: Singapore purchasing for an overseas branch looks to that branch’s end-customer supply. Uncertainty over when/to whom local shares will be sold does not make purchase input residual; it is attributable to exempt shares unless intended for sale to an overseas person. Evaluative due diligence on a potential target is a step removed from acquisition and any future share supply, whether or not the deal completes; it is generally residual business expenditure, unlike the actual share-acquisition input.
Version changes and practical records
The log records first-issue and branch/due-diligence clarifications in 2019, DPT/payment-service additions in 2020, termination clarifications in 2021/2022, LVG changes for 2023 and residual-input wording clarified in October 2025. Keep the accounting cost/use rationale, transaction chain and retained calculator. Enquiries go to IRAS GST through Contact Us. For charities subsidising or providing free activities, the guide points to the separate charity/non-profit rules rather than assuming all grant-funded input is taxable-use input.
Official source
This article independently explains the substantive contents of the official PDF, including the relevant conditions, procedures and annexes. The linked document remains the authoritative source for its original wording, and later changes should be checked separately.
Read the official PDF ↗