Tax Treatment of Foreign-Sourced Income

Tax Treatment of Foreign-Sourced Income 境外收入的税收处理

In Singapore, taxes are imposed on income earned or accrued in Singapore, as well as foreign-sourced income remitted into Singapore. The Government has received feedback that while a company may qualify for foreign tax credit to offset the taxes payable on remitted foreign-sourced income, it may find the tax credit system administratively cumbersome. 在新加坡,对在新加坡赚取或累算的收入以及汇往新加坡的外国收入征税。政府收到的反馈是,虽然一家公司可能有资格申请外国税收抵免,以抵消其在国外汇入的收入所应缴纳的税款,但它可能会发现税收抵免制度在行政上很麻烦。

The Government has therefore introduced the foreign-sourced income exemption regime (FSIE) as a simplified regime mirroring the foreign tax credit system. 因此,政府引入了外国来源的收入豁免制度(FSIE),作为一个简化的制度,反映了外国税收抵免制度。

FSIE – Section 13(8) of the Income Tax Act 《所得税法案》第13(8)条

Under the FSIE regime, the Government announced that foreign-sourced dividends, branch profits and service income (collectively “specified foreign-sourced income”) derived by any person resident in Singapore will be exempted from tax if the following conditions are met: 在FSIE制度下,政府宣布,任何居住在新加坡的个人取得的外国来源股息、分行利润和服务收入(统称“指定外国来源收入”),如符合下列条件,可获豁免缴税:
 
i. the specified foreign-sourced income has been subjected to tax in the foreign jurisdiction from which the income is received; (一)指定的境外所得,在境外取得的;
 
ii. the headline tax rate of the foreign jurisdiction from which the specified foreign-sourced income is received is at least 15%; and (二)指定的境外收入来源所在境外管辖区的总体税率至少为15%;和
 
iii. the Comptroller is satisfied that the tax exemption would be beneficial to the person resident in Singapore. (三)主计长认为免税对居住在新加坡的人有利。

FSIE – Section 13(12) of the Income Tax Act FSIE -《所得税法案》第13(12)条

Where the above conditions cannot be met, tax exemption may be granted under section 13(12) of the Income Tax Act on foreign-sourced income which falls within the scenarios specified in the  IRAS e-tax guide  on “Income Tax: Tax Exemption under Section 13(12) for Specified Scenarios, Real Estate Investment Trusts and Qualifying Offshore Infrastructure Project/Asset”. 在上述条件不能满足,免税授予下一节13(12)的所得税法对来源于外国收入属于场景中指定ira e-tax指南”所得税:免税部分13(12)为指定的场景下,房地产投资信托和排位赛海上基础设施项目/资产”。
 
Applications for tax exemption under section 13(12) on the foreign-sourced income which do not fall within the scenarios can be made to the Ministry of Finance before the foreign income is received in Singapore. 根据第13(12)条,外国来源的收入如不属于上述情况,可在外国收入在新加坡收到之前,向财政部提出免税申请。

For more details on claiming the tax exemption under the FSIE regime, please refer to the information and e-tax guides found at IRAS’ website . 如欲获得更多有关在FSIE制度下申请免税的详情,请参阅税务局网站的资料及电子税务指南。

Foreign Tax Credit Pooling 国外税收抵免联营

The Government has also introduced foreign tax credit pooling, provided that the following conditions are met: 政府还引入了国外税收抵免池,前提是满足以下条件:
 
i. income tax is paid on the income in the foreign jurisdiction from which the income is derived; (一)所得是在外国境内取得的;
 
ii. the headline tax rate of the foreign jurisdiction from which the income is received is at least 15% at the time the foreign income is received in Singapore; and 二世。在新加坡收到境外收入时,境外收入所在管辖区的总体税率至少为15%;和
 
iii. there is Singapore income tax payable on the foreign income and the taxpayer is entitled to claim for foreign tax credit under the Income Tax Act. 三世。根据《所得税法》,外国所得需缴纳新加坡所得税,纳税人有权申请外国税收抵免。
 
Please refer to  IRAS’ website  for more details on the foreign tax credit pooling system. 有关外国税收抵免联营制度的详情,请参阅税务局网站。
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