Taxation of international executives
Are there special residency considerations for short-term assignments?
A non-resident individual, other than a director, exercising an employment in Singapore for not more than 60 days in a calendar year is exempt from tax on income arising from that short-term employment. If possible, it may be beneficial to structure short-term assignment such that the 60-day exemption applies.
Singapore currently has tax treaties with several countries/jurisdictions that may provide exemption for dependent services for short-term employment, subject to conditions.
Are there special payroll considerations for short-term assignments?
Tax treaty exemption would generally require that the payroll costs must not be borne by a permanent establishment in Singapore.
What income will be taxed during short-term assignments?
An employee who exercises employment in Singapore will be liable to Singapore income tax on the remuneration (including all benefits, whether in money or otherwise, unless they are specifically exempted from income tax or are covered by an existing administrative concession) payable to them for their services rendered in Singapore even though the remuneration may be paid outside Singapore.
Are there any additional considerations that should be considered before initiating a short- term assignment in Singapore?
Where for certain reasons (e.g. length of assignment, cost-charging arrangements etc.) tax treaty exemption of the employment income in Singapore is not possible, careful planning of the short-term assignment start and end dates may result in tax savings.
Separately, there may be filing requirements to be fulfilled by the employer / employee pursuant to the short-term assignment, notwithstanding that tax-exemption may apply in accordance to the local tax laws or the double-taxation agreement.
All information contained in this publication is summarized by KPMG Services Pte. Ltd., a Singapore incorporated company and a member firm of the KPMG network of independent member firms affiliated with KPMG International Cooperative ("KPMG International"), a Swiss entity, based on relevant provisions of the Singapore income tax legislations, regulations issued thereunder and judicial and administrative interpretations thereof, and the web sites of the Inland Revenue Authority of Singapore, Central Provident Fund Board, Ministry of Manpower, Monetary Authority of Singapore and Personal Data Protection Commission.
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