Key Tax Incentives EDB ES

Key Tax Incentives Administered by the Economic Development Board and Enterprise Singapore

23/10/2024
Key Tax Incentives EDB ES

The Singapore government has established a number of tax incentive programmes to help companies improve efficiency, strengthen capabilities and explore new opportunities in their business. Some programmes cater to the needs of start-ups and local enterprises, while others are designed for global companies carrying out high-value and substantive economic activities in Singapore.

The tax incentives are legislated, and the approving authority is usually vested with statutory bodies such as the Economic Development Board (EDB), Enterprise Singapore (ES), the Monetary Authority of Singapore (MAS), the Singapore Tourism Board (STB), the Building and Construction Authority (BCA), and the Maritime and Port Authority of Singapore (MPA).

The key tax incentives administered by EDB and ES are listed below:

Incentives Table
Business Sector/Activity Incentive Tax Relief Relief Period Sunset Clause Qualifying Criteria Legislation Administrative Body
Venture Capital Venture Capital Fund Incentive (VCFI)
  • Tax exemption on qualifying income
  • Goods and services tax (GST) remission on expenses at a fixed recovery rate
Qualifying Income:
  • Dividends derived from outside Singapore and received by the company in Singapore from approved investments in any company not resident in Singapore
  • Interest derived from outside Singapore and received by the company in Singapore in respect of any approved convertible loan stock of a company not resident in Singapore, and
  • Gains or profits derived from Singapore or received by the company in Singapore from outside Singapore from the disposal of any approved investment
Life of the venture capital fund, up to a maximum of 15 years 31 December 2025
The VCFI scheme requires that the fund:
  • Has a minimum fund size of S$10 million
  • Incurs cumulative local business spending (LBS) of at least S$100,000 multiplied by the incentive tenure, to be met by the end of the incentive tenure
  • Invests a certain percentage into unlisted Singapore-based companies by Year 5 of the incentive or by the end of the incentive, whichever is earlier

The VCFI scheme accommodates the following legal structures:

  • Limited partnership
  • Company (incorporated in Singapore or elsewhere), and
  • Variable Capital Company (VCC)
Section 13G of the Income Tax Act 1947, Income Tax (Exemption of Income of Approved Venture Company) Regulations ES
Venture Capital Fund Management Incentive (FMI) Concessionary tax rate of 5% on qualifying income derived from managing venture capital funds approved under the VCFI

Qualifying Income:

  • Management fees
  • Performance bonuses
Five (5) years, renewable in tranches of up to 5 years 31 December 2025 Fund managers who have obtained the necessary MAS license are eligible to apply for the FMI. The FMI requires that the fund manager:
  • Has a minimum assets under management (AUM) of S$40 million comprising VCFI funds
  • Hires at least one (1) additional investment professional by the end of the FMI award. For renewals, the fund manager must hire at least 1 additional investment professional by the end of the renewal tranche
Section 43V of the ITA ES
Global Trading Global Trader Programme Concessionary tax rate of 5%, 10%, or 15% on qualifying income

Qualifying Income

  • Profits from any physical trading carried out by the company in the commodities specified for the company
  • Profits from any trading in any derivative instrument carried out by the company
  • Commission and fees from acting as broker in any physical trading in the commodities specified for the company
  • Income from the carrying on of any prescribed qualifying structured commodity financing activity, prescribed treasury activity or prescribed advisory services in relation to mergers and acquisitions, specified for the company
Five (5) years, renewable in tranches of up to 5 years 31 December 2026 Established companies engaged in international physical trading that are able to commit to the following in Singapore:
  • Conduct significant trading activities
  • Employ skilled professionals
  • Perform strategic functions such as strategic management, compliance and risk management, financial management, and logistics management functions
  • Make significant use of Singapore’s banking and financial services, logistics, arbitration, and other supporting services
Section 43I of the ITA, Income Tax (Concessionary Rate of Tax for Global Trading Companies) Regulations 2016 ES
Treasury Management Finance and Treasury Centre (FTC) Incentive
  • Concessionary tax rate of 8% or 10% on income derived from qualifying FTC services to approved network companies (ANCs) and qualifying FTC activities carried out by the FTC on its own account with funds obtained from qualifying sources
  • Withholding tax exemption on interest payments on loans from banks and non-bank financial institutions outside Singapore and loans and deposits from ANCs outside Singapore, where the loans relate to the conduct of qualifying FTC services and activities
Five (5) years, may be renewed in tranches of up to 5 years 31 December 2026 8% Concessionary Tax Rate:

For initial award:

  • Carry out any of the FTC activities in Singapore
  • Employ at least Four (4) FTC professionals, all of whom shall be based in Singapore by Year 1, and maintain this until the end of the incentive period
  • Incur annual total business expenditure (TBE) of at least S$1.5 million for the FTC by Year 1, and maintain this until the end of the incentive period

For subsequent renewals:

  • Carry out any of the FTC activities in Singapore
  • Employ at least one (1) additional FTC professional by Year 5, all of whom shall be based in Singapore
  • Incur annual total business expenditure (TBE) of at least S$400,000 for the FTC by Year 1, and maintain this until the end of the incentive period
10% Concessionary Tax Rate:

For initial award:

  • Carry out any of the FTC activities in Singapore
  • Employ at least three (3) FTC professionals, all of whom shall be based in Singapore by Year 1, and maintain this until the end of the incentive period
  • Incur annual TBE of at least S$1.5 million for the FTC by Year 1, and maintain this until the end of the incentive period

For subsequent renewals:

  • Carry out any of the FTC activities in Singapore
  • Employ at least one (1) additional FTC professional by Year 5, all of whom shall be based in Singapore
  • Incur an additional annual TBE of at least S$350,000 by Year 5
Section 43E of the ITA, Income Tax (Concessionary Rate of Tax for Approved Finance and Treasury Centre) Regulations 2017 EDB
Aviation Aircraft Leasing Scheme (ALS)
  • Concessionary tax rate of 8% or 10% on income derived from the leasing of aircraft or aircraft engine and qualifying ancillary activities
  • Withholding tax exemption on interest and qualifying related payments on loans obtained for the purchase of aircraft or aircraft engines
  • Irrevocable election to depreciate the aircraft over any number of years from five (5) to 20 years
Five (5) years, may be renewed in tranches of up to 5 years 31 December 2027 8% Concessionary Tax Rate:

For initial award:

  • Employ at least five (5) additional skilled employees, all of whom shall be based in Singapore, by Year 5
  • Incur annual total business spending (TBS) of at least S$15 million by Year 5

For subsequent renewals:

  • Employ at least one (1) additional skilled employee, all of whom shall be based in Singapore, by Year 5
  • Incur annual TBS of at least S$17 million by Year 5
10% Concessionary Tax Rate

For initial award:

  • Employ at least five (5) additional skilled employees, all of whom shall be based in Singapore, by Year 5
  • Incur annual TBS of at least S$13.5 million by Year 5

For subsequent renewals:

  • Employ at least one (1) additional skilled employee, all of whom shall be based in Singapore, by Year 5
  • Incur annual TBS of at least S$15.5 million by Year 5
Section 43N of the ITA, Income Tax (Concessionary Rate of Tax for Aircraft Leasing Company) (Prescribed Activities) Regulations 2008, Income Tax (Concessionary Rate of Tax on Dividends — Aircraft Leasing Company) Order 2020 EDB
Aviation Aircraft Investment Manager (AIM) Incentive Concessionary tax rate of 10% on income arising from qualifying activities:
  • Managing an approved aircraft leasing company and approved special purpose companies, and
  • Provision of investment advisory services for and to an approved aircraft leasing company
Five (5) years 31 December 2027 The AIM is awarded as a tie-in with ALS, therefore only companies that will be managing or providing investment advisory services to an approved aircraft leasing company applying for or having an existing ALS may apply Section 43O of the ITA, Income Tax (Concessionary Rate of Tax for Aircraft Investment Manager) (Prescribed Activities) Regulations 2008 EDB
Research and Development Intellectual Property Development Incentive (IDI) Concessionary tax rate on a percentage of qualifying Intellectual Property (IP) income derived during the incentive period

Concessionary tax rate offered will correspond to the primary incentive which the entity is enjoying or applying for:

  • Pioneer Service Incentive: 5%
  • Development and Expansion Incentive (including Headquarters) – 5%: 5%
  • Development and Expansion Incentive (including Headquarters) – 10%: 10%
Qualifying intellectual property income refers to royalties or other income receivable by the approved company as consideration for the commercial exploitation of an elected qualifying intellectual property right
10 years, may be renewed in tranches of up to 10 years 31 December 2028 5% Concessionary Tax Tate (Standalone Award)

For every five (5)-year qualifying period:

  • Employ at least 20 additional skilled employees, all of whom shall be based in Singapore by Year 5
  • Incur additional annual TBE of at least S$10.5 million by Year 5
10% Concessionary Tax Rate (Standalone Award)

For every 5-year qualifying period:

  • Employ at least 20 additional skilled employees, all of whom shall be based in Singapore by Year 5
  • Incur additional annual TBE of at least S$7 million by Year 5.
Section 43X of the ITA, Income Tax (Concessionary Rate of Tax for Intellectual Property Income) Regulations 2021 EDB
Research and Development Approved Royalties Incentive Tax exemption or concessionary withholding tax rate on approved royalties, technical assistance fees, or contributions to research and development costs As specified in the approval certificate 31 December 2028 Company must enter into, or desire to enter into, an agreement or arrangement with a non‑resident person for the purposes of carrying on an approved activity under which royalties or technical assistance fees or contributions to research and development costs are or will be payable to the non‑resident person Part 7 of the Economic Expansion Incentives (Relief from Income Tax) Act 1967 (EEIA) EDB
Growth Pioneer Certificate Incentive — Pioneer Industries (Manufacturing) Tax exemption on income derived from the manufacturing of the pioneer product(s) Five (5) years, up to a maximum of 15 years 31 December 2028

Company must:

  • Incur additional Fixed Asset Investment (FAI) of at least S$44 million by Year 5
  • Employ at least 30 additional skilled employees, all of whom shall be based in Singapore by Year 5
Part 2 of the Economic Expansion Incentives (Relief from Income Tax) Act 1967 EDB
Growth Pioneer Certificate Incentive — Pioneer Service Companies Tax exemption on income derived from qualifying activities:
  • Engineering or technical services including laboratory, consultancy and research and development activities
  • Computer-based information and other computer related services
  • The development or production of any industrial design, and
  • Such other services or activities as may be prescribed
Five (5) years, up to a maximum of 15 years 31 December 2028 Company must engage in, or desire to engage in, one or more qualifying activities Part 3 of the Economic Expansion Incentives (Relief from Income Tax) Act 1967, Expansion Incentives (Relief from Income Tax)(Qualifying Activity) Regulations, Economic Expansion Incentives (Relief from Income Tax) (Intellectual Property Income) Regulations 2018 EDB
Growth Development and Expansion Incentive (DEI) for Manufacturing Concessionary tax rate of 5%, 10%, or 15% on income over base income

Qualifying income refers to income derived from qualifying manufacturing activities undertaken in Singapore

The base income is the average income from qualifying activities of the entity for the 36 months immediately preceding the DEI

Five (5) years, may be renewed in tranches of up to 5 years, up to a maximum of 40 years 31 December 2028 5% Concessionary Tax Rate

For every five (5)-year qualifying period:

  • Incur additional FAI of at least S$13 million by Year 5
  • Employ at least 30 additional skilled employees, all of whom shall be based in Singapore by Year 5
10% Concessionary Tax Rate

For every 5-year qualifying period:

  • Incur additional FAI of at least S$7 million by Year 5
  • Employ at least 20 additional skilled employees, all of whom shall be based in Singapore by Year 5
15% Concessionary Tax Rate

For every 5-year qualifying period:

  • Incur additional FAI of at least S$5 million by Year 5
  • Employ at least 13 additional skilled employees, all of whom shall be based in Singapore by Year 5
Part 4 of the Economic Expansion Incentives (Relief from Income Tax) Act 1967 EDB
Growth DEI for Services Concessionary tax rate of 5%, 10% or 15% on qualifying income in excess of the base income

Qualifying income refers to income derived from qualifying services or activities (excluding headquarters and manufacturing activities) undertaken in Singapore

The base income is the average income from qualifying activities of the entity for the 36 months immediately preceding the DEI

Five (5) years, may be renewed in tranches of up to 5 years, up to a maximum of 40 years 31 December 2028 5% Concessionary Tax Rate

For every five (5)-year qualifying period:

  • Carry out at least one service activity
  • Employ at least 18 additional skilled employees, all of whom shall be based in Singapore by Year 3
  • Incur additional annual TBE of at least S$8 million by Year 3
  • Employ at least 30 additional skilled employees, all of whom shall be based in Singapore by Year 5
  • Incur additional annual TBE of at least S$13 million by Year 5
10% Concessionary Tax Rate

For every five (5)-year qualifying period:

  • Carry out at least one service activity
  • Employ at least 15 additional skilled employees, all of whom shall be based in Singapore by Year 3
  • Incur additional annual TBE of at least S$5.5 million by Year 3
  • Employ at least 25 additional skilled employees, all of whom shall be based in Singapore by Year 5
  • Incur additional annual TBE of at least S$9 million by Year 5
15% Concessionary Tax Rate

For every five (5)-year qualifying period:

  • Carry out at least one service activity
  • Employ at least eight (8) additional skilled employees, all of whom shall be based in Singapore by Year 3
  • Incur additional annual TBE of at least S$3 million by Year 3
  • Employ at least 13 additional skilled employees, all of whom shall be based in Singapore by Year 5
  • Incur additional annual TBE of at least S$5 million by Year 5
Part 4 of the Economic Expansion Incentives (Relief from Income Tax) Act 1967, Economic Expansion Incentives (Relief from Income Tax) (Qualifying Activity) Regulations, Economic Expansion Incentives (Relief from Income Tax) (Intellectual Property Income) Regulations 2018 EDB
Headquarters Development and Expansion Incentive (DEI) for Manufacturing — International Headquarters Award Concessionary tax rate of 5%, 10% or 15% on qualifying income in excess of the base income

Qualifying Activities:

  • Management, coordination and control functions of business activities for the group
  • Sourcing and procurement
  • Supply chain managementp
  • Marketing control and planning
  • Human resource management
  • Provision of legal services
  • Provision of finance services
  • Provision of brand management services
Five (5) years 31 December 2028 5% Concessionary Tax Rate

For every five (5)-year qualifying period:

  • Carry out at least one (1) of the headquarters activities in Singapore
  • Employ at least 18 additional skilled employees, all of whom shall be based in Singapore by Year 3
  • Incur additional annual TBE of at least S$8 million by Year 3
  • Employ at least 30 additional skilled employees, all of whom shall be based in Singapore by Year 5
  • Incur additional annual TBE of at least S$13 million by Year 5.
10% Concessionary Tax Rate

For every five (5)-year qualifying period:

  • Carry out at least one of the headquarters activities in Singapore
  • Employ at least 15 additional skilled employees, all of whom shall be based in Singapore by Year 3
  • Incur additional annual TBE of at least S$5.5 million by Year 3
  • Employ at least 25 additional skilled employees, all of whom shall be based in Singapore by Year 5
  • Incur additional annual TBE of at least S$9 million by Year 5
15% Concessionary Tax Rate

For every five (5)-year qualifying period:

  • Carry out at least one (1) of the headquarters activities in Singapore
  • Employ at least eight (8) additional skilled employees, all of whom shall be based in Singapore by Year 3
  • Incur additional annual TBE of at least S$3 million by Year 3
  • Employ at least 13 additional skilled employees, all of whom shall be based in Singapore by Year 5
  • Incur additional annual TBE of at least S$5 million by Year 5
Part 4 of the Economic Expansion Incentives (Relief from Income Tax) Act 1967 EDB
Productive Equipment Approved Foreign Loan Scheme Tax exemption or concessionary withholding tax rate on interest payments made to a non-resident for loans to a company to purchase productive equipment As specified in the approval certificate 31 December 2028 Company must obtain, or desire to obtain, a loan of not less than $20 million from a non‑resident person by means of an agreement under which credit facilities are granted for the purchase of productive equipment for the purposes of its trade or business Part 6 of the Economic Expansion Incentives (Relief from Income Tax) Act 196 (EEIA) EDB
Productive Equipment Investment Allowance for Emissions Reduction Investment allowance of a specified percentage not exceeding 100% of the amount of the fixed capital expenditure incurred on an approved project for reducing greenhouse gas emissions Five (5) years 31 December 2026 Company must carry out a project that reduces greenhouse gas emissions Part 8 of the EEIA EDB
Productive Equipment Investment Allowance for Automation 100% investment allowance on approved capital expenditure for approved automation projects, capped at S$10 million per project Five (5) years 31 March 2026 Company must engage in large scale deployment of automation solutions to improve resource efficiency through automation and technology Part 8 of the EEIA ES

The information presented in this article is as at 23 October 2024.

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This article should be used as a general guide only. No reader should act solely upon any information found in this article. We recommend that professional advice be sought before taking action on specific issues and making significant business decisions. Crowe Singapore expressly disclaims all and any liability to any person in respect of anything, and of the consequences of anything, done or omitted to be done by any such person in reliance, whether wholly or partially, upon the whole or any part of the contents of the above article. While every effort has been made to ensure the accuracy of the information contained herein, Crowe Singapore shall not be responsible whatsoever for any errors or omissions in it.

 

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