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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 |