Registering for Goods and Services Tax

Registering for Goods and Services Tax

31/05/2024
Registering for Goods and Services Tax

Goods and Services Tax (GST) is a consumption tax levied on nearly all supplies of goods and services in Singapore by any taxable person in the course or furtherance of a business, as well as upon the import of goods into Singapore. GST is also levied on imports of services and low-value goods.

A taxable person is a person who is already GST-registered or is required to be GST-registered under the Goods and Services Tax Act 1993 (GST Act). It is important that businesses are aware of the GST registration requirements in Singapore as late registration or failure to register when required to do so is an offence and penalties may be imposed.

Compulsory Registration 

Businesses are required to register for GST, if at any time, they expect or there is certainty that the taxable turnover1 in the next 12 months will exceed S$1 million. This is referred to as “compulsory registration on a prospective basis”.

Businesses are also required to register for GST if the taxable turnover at the end of the calendar year had exceeded S$1 million. This is referred to as “compulsory registration on a retrospective basis”.

A business may also be liable for GST registration under the:

  • reverse charge mechanism if the business procures services from overseas suppliers or imports low-value goods and the business is not entitled to full input tax credit even if it is GST-registered, or
  • overseas vendor registration regime if the business is an overseas supplier or a local/overseas electronic marketplace operator or redeliverer that provides services (digital and non-digital) or supplies imported low-value goods to non-GST registered individuals and businesses in Singapore.

Reverse Charge Mechanism 

Under the reverse charge mechanism, GST-registered businesses belonging in Singapore which are not entitled to full input tax claims must account for GST, as if they were the supplier, on business-to-business imported services and low-value goods. Local businesses that are liable for GST registration or are already GST-registered are also required to account for GST on business-to-consumer sales of low-value goods to non-GST registered customers in Singapore.

Imported services refer to services procured from overseas suppliers.

Low-value goods are goods which at the point of sale:

  • are not dutiable goods, or are dutiable goods, but payment of the customs duty or excise duty chargeable on the goods is waived under section 11 of the Customs Act 1960
  • are not exempt from GST
  • are located outside Singapore and are to be delivered to Singapore via air or post, and
  • have a value not exceeding the GST import relief threshold of S$400.

Local Supplier

A non-GST registered local supplier who would not be entitled to full input tax credit even if it were GST-registered, must include the annual value of its imported services and low-value goods to determine whether it is liable for GST registration.

The local supplier is required to register for GST if:

  • its taxable turnover, and/or
  • the total value of its imported services and low-value goods

Local Supplier with Low-Value Goods Outside Singapore

A non-GST registered local supplier who makes direct sales of low-value goods to customers who are not GST-registered in Singapore must include such supplies in its taxable turnover in determining its GST registration liability.

Direct sales refer to goods that are supplied directly by local and overseas suppliers to customers who are not GST-registered in Singapore (e.g., through the supplier’s own website), instead of supplying the goods through an electronic marketplace or redeliverer.

Local Electronic Marketplace Operator

An electronic marketplace is a medium that:

  • allows the suppliers to make supplies available to customers, and
  • is operated by electronic means.

This includes marketplaces operated via a website, internet portal, gateway, distribution platform or any other types of electronic interface, but excludes payment processors or internet service providers.

A local operator of an electronic marketplace who is not GST-registered must include the value of the following business-to-consumer supplies to determine its GST registration liability:

  • low-value goods supplied by local and overseas suppliers through the marketplace
  • remote services supplied by overseas suppliers through the marketplace.

Remote services generally refer to services where the recipient of the services need not be at the location where the services are physically performed in order to enjoy/consume the services.

Local Redeliverer

A redeliverer is a person who arranges with the customer to:

  • deliver or facilitate the delivery of goods to Singapore, and
  • provide or facilitate the use of an address outside of Singapore for delivery of the goods, or
  • purchase or facilitate the purchase of the goods.

A local redeliverer who is not GST-registered must include the value of business-to-consumer supplies of low-value goods that it assists to purchase and/or deliver to a customer in Singapore, to determine its GST registration liability.

Overseas Vendor Registration Regime

Under the overseas vendor registration regime, GST-registered overseas vendors must account for GST on business-to-consumer supplies of remote services and low-value goods made to customers in Singapore. These overseas businesses will be registered under a simplified pay-only regime.

Overseas Supplier

An overseas supplier is required to register for GST in Singapore if it:

  • has an annual global turnover exceeding S$1 million, and
  • makes business-to-consumer supplies of remote services and/or low-value goods to customers in Singapore exceeding S$100,000 annually.

Overseas Electronic Marketplace Operator 

An overseas operator of an electronic marketplace must include the value of the following business-to-consumer supplies made through its marketplace to determine its GST registration liability:

  • low-value goods made by local and overseas suppliers through the marketplace
  • remote services made by overseas suppliers through the marketplace.

Overseas Redeliverer

An overseas redeliverer must include the value of business-to-consumer supplies of low-value goods that it assists to purchase and/or deliver to a customer in Singapore, to determine its GST registration liability.

Voluntary Registration

A business may apply to be GST-registered on a voluntary basis even if it is not compulsory for the business to register for GST.

To qualify for voluntary registration, the business must either:

  • make taxable supplies
  • make only out-of-scope supplies
  • make exempt supplies of financial services that are also international services as described in section 21(3) of the GST Act, or
  • procure services from overseas service providers or import low-value goods and would not be entitled to full input tax credit even if it were GST-registered.

The business must fulfil several conditions before and after registering for GST on a voluntary basis.

Application for Registration for GST

Where a business is liable to register for GST on a compulsory basis, it has to do so online at mytax.iras.gov.sg within 30 days from the date the liability to register arises, either on a prospective or retrospective basis.

Thereafter, a letter bearing the GST registration number and the effective date of GST registration will be sent to the business when the registration is approved.

A business that is GST-registered on a voluntary basis must remain GST-registered for at least two (2) years and must comply with certain conditions imposed by the Inland Revenue Authority of Singapore (IRAS) during the period of its registration.

Overseas Entities 

An overseas entity is one that has neither a business establishment, fixed establishment nor usual place of residence in Singapore.

An overseas entity importing goods for supply in Singapore may adopt one of the following options:

  1. Option 1: The overseas entity may import goods into Singapore and supply them in its own business name. If the overseas entity’s taxable supplies in Singapore exceed the S$1 million threshold, GST registration is compulsory. If the overseas entity registers for GST, the overseas entity must appoint a local agent in Singapore, known as a section 33(1) agent, who will act on the overseas entity’s behalf for all its GST matters. This agent is responsible for the accounting and payment of GST.
  2. Option 2: The overseas entity may appoint a GST-registered Singapore agent who will import and supply goods on the overseas entity’s behalf. This agent, known as a section 33(2) agent, is responsible for the imported goods as if the agent is the principal. The agent will import goods into Singapore in the agent’s name and claim the GST paid on imports. Subsequent supplies of the goods imported will be treated as the agent’s own taxable supplies. The agent must account for GST on these supplies. The overseas entity does not need to register for GST.

Group Registration 

Group registration allows several companies to report GST as a group instead of reporting individually.

Under group registration, one of the companies will be nominated by the group as the representative member. The GST registration is in the name of the representative member.

To qualify for group registration, companies must satisfy certain conditions.

The Comptroller of GST can refuse an application for group registration for the protection of revenue.

Divisional Registration 

Divisional registration allows independent divisions within a company, or a sole-proprietor who owns several sole-proprietorship businesses, to account and report GST separately.

Each division will be assigned a unique registration number. The company or sole proprietor may apply for divisional registration for some divisions while accounting for the remaining divisions under the GST registration number of the company or sole proprietor.

To be eligible for divisional registration, the company or sole proprietor must meet certain conditions.

A division shall remain separately registered for at least two (2) years or such other shorter period as the Comptroller may allow.

Registration for Joint Ventures

A joint venture is a business arrangement where 2 or more parties (members) come together to carry out certain activities jointly. If registered with the Accounting and Corporate Regulatory Authority (ACRA), a joint venture is a legal entity and can be registered for GST.

If not registered with ACRA, a joint venture can only be registered for GST if certain conditions are fulfilled.

Late Registration or Failure to Register

The consequences for late registration or failure to register for GST include the following:

  1. A fine of up S$10,000
  2. A penalty equal to 10% of the tax due
  3. Prosecution action by the Comptroller
  4. A further penalty of S$50 for every day during which the offence continues after conviction, and
  5. Backdating of the effective date of GST registration to the date on which the business ought to have been registered. GST on taxable supplies made from the effective date of GST registration has to be paid even if no GST was collected from the customers. 

More guidance on GST registration can be found in the following IRAS e-Tax Guides:

________________

  • 1Taxable turnover consists of standard-rated and zero-rated supplies. Exempt supplies and transactions that are out of scope are not included as part of taxable turnover.
  • Standard-rated supplies include local sales and local provision of services, including the supply of imported low-value goods to individuals and businesses in Singapore that are not registered for GST.
  • Zero-rated supplies include the export of goods from Singapore and provision of international services as described in section 21(3) of the GST Act.
  • Exempt supplies include the sale and lease of bare residential property and most financial services provided to overseas persons.
  • Out-of-scope supplies include third country sales where the goods do not come into Singapore, goods in transit and private transactions.

How we can help.

As GST registration obligation is an on-going obligation which non-GST registered businesses need to monitor on a periodic basis, we will advise businesses to put in place controls or reminders to review their obligation. Failure to comply usually results in material financial hardship to businesses.

We offer the following GST services:

  • GST advisory
  • GST compliance
  • GST health-check and risk assessment.

If you require our assistance on this matter, please do not hesitate to contact us at [email protected]

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Sivakumar Saravan Crowe Singapore
Sivakumar Saravan
Senior Partner
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Liew Kin Meng
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Goh Wai Gang
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