Foreign-Sourced Income Exemption (FSIE)
 

The concession proposed by the Finance Minister is to grant exemption for foreign income that is disqualified from the FSIE regime if it is remitted under specific scenarios or circumstances. Details are to be released by the IRAS in due course.  

The FSIE was introduced in 2003 as a means of reducing the administrative burden of the foreign tax credit system it replaces, and encouraging the tax-free repatriation of funds to Singapore.  Under S13(8) of the ITA, tax exemption is granted to all persons resident in Singapore on their specified foreign income received in Singapore on or after 1st January 2003, provided:

-  the specified foreign income has been subjected to tax in the foreign jurisdiction from which the income is received,

-   at the time the specified foreign income is received in Singapore, the headline tax rate of the foreign jurisdiction is at least 15%

In Budget 2004, DPM and Minister for Finance announced his decision to exempt from tax all foreign-sourced income received in Singapore directly by resident individuals on or after 1st January 2004. As a consequence of this enhancement, the need to meet the conditions for tax exemption of the specified foreign income would therefore be applicable to resident persons other than individuals, and resident individuals receiving the specified foreign income through a partnership in Singapore.

The Government has also decided to grant a tax concession to regard the “subject to tax condition” as met for the specified foreign income which are exempt from tax if the exemption is a tax incentive granted for carrying out substantive business activities in foreign jurisdiction.

Further details can be achieved here

http://www.iras.gov.sg/ESVPortal/resources/2004it8.pdf

Updated July 2006