Identify payments and partner composition
Specified payments such as interest, royalties and management fees to non-residents can require deduction and payment of withholding tax. For a partnership, the relevant amount is the portion attributable to non-resident partners, including service payments. The source states that the section 45 withholding requirement is waived for partnerships with at least one resident partner, in view of their annual Form P reporting.
All-non-resident partnerships and changes
A partnership with wholly non-resident partners must submit a head-office undertaking accepting liability for outstanding tax arising from the waiver if the Singapore partnership defaults. Notify the Comptroller immediately when withdrawal of resident partners changes the composition to wholly non-resident. To continue the waiver, submit the undertaking with the change notification. Do not assume an earlier waiver continues automatically after the composition changes.
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.
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