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Taxes · PDF

Non-Resident Company Withholding: Follow the Treaty Decision Path

The flowchart starts with Singapore-source income under sections 12(6) and 12(7) and tests treaty allocation of taxing rights.

Source checked · 11 October 2026

Identify the income article before relying on no PE

Check whether the recipient is resident in a treaty partner and whether a specific treaty article governs the payment. If business profits applies, assess the permanent establishment and the income’s connection to it; a specific royalty or interest article may instead permit source taxation at a treaty rate. Domestic law applies without treaty entitlement. No Singapore PE is therefore not a universal exemption for every kind of payment.

Read the footnotes and treaty version

The chart explains that Australia’s non-individual service income follows business profits from 1 May 2018, while the revised Korea treaty from 1 January 2020 changes the earlier professional-service analysis. Other treaties can retain different service provisions. Review the correct treaty, residence evidence and transaction facts, then report or claim relief through IRAS. The chart guides classification; it does not replace the actual treaty text or provide a single rate for all non-resident companies.

Official source

A concise, independent Apex Gateway guide based on the official English source, not a reproduction of the complete document. Consult the original for full conditions, exceptions and subsequent updates.

Read the official PDF ↗
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