GST Belonging Status: Supplier and Customer Establishments

Key steps and distinctions

Belonging status affects whether services are supplied in Singapore and whether a zero-rating provision can apply. A person with business or fixed establishments only in Singapore belongs here. When establishments exist in several countries, the supplier belongs where the establishment most directly concerned with the supply is located; the recipient belongs where the services are most directly used or intended to be used. Without either type of establishment, usual residence determines the result. A company’s usual residence is its place of incorporation or legal constitution, but incorporation alone does not override an actual business establishment elsewhere. A business establishment may be the main seat of economic activity, a branch or a qualifying agency. Essential management decisions and central administration are relevant to the main seat, while an office or other permanent place does not automatically establish all required characteristics. Agency arrangements require examination of control, independence, functions and substance. Determine both the contracting customer and direct beneficiary where a zero-rating rule requires it. This analysis concerns GST only and is not an income-tax residence or tax-treaty determination. Imported-service, remote-service and low-value-goods regimes have their own additional rules, including administrative customer-location evidence.