T&L newsletter - Singapore certificates of residence
19 Dec 2022Dear Readers,
In this issue of our newsletter, we offer you an overview of some of the specifics applied by the local tax authorities in the verification of certificates of tax residence issued by the Singaporean authorities.
A local taxpayer received a letter of advice from the Kazakhstan tax authorities in relation to a certificate of tax residence provided by its service provider from Singapore. According to this letter, the tax authorities question the exemption from income tax withholding (WHT) applied by the taxpayer in 2019 in relation to the Kazakh-sourced income of this service provider since the certificate does not meet all the requirements of the local tax legislation (Art 675 of the Tax Code).
The tax authorities’ letter does not disclose any details of what requirement the certificate does not meet. According to additional details received from the tax authorities, the certificate issued by the Singapore authorities indicating "Year of assessment - 2019"[1] proves the period of tax residence from 1 January 2018 to 31 December 2018 instead of 2019. This position is supported by a letter from the Singapore tax authorities received by the Kazakhstan tax authorities in response to their request to the Singapore tax authorities on the meaning of the term "Year of assessment".
It is worth mentioning that the certificate received by the taxpayer indicates nothing about the above specifics. There are also no official agreements between Kazakhstan and Singapore authorities describing these specifics.
Our team provides a wide range of tax advisory services, including tax dispute resolution. We will be happy to discuss any questions you may have or support you during tax audits.
Sincerely,
Grant Thornton Tax team
[1] This term is translated into Russian as “Год [налого]обложения – 2019” or “Year of [tax] assessment – 2019”. It means a year in which income received is taxed. Generally, this is the year following a corresponding tax period. For example, income earned during the 2018 calendar year is taxed in an income tax return that is filed in the following year, i. e. 2019. In this example, the "year of [tax] assessment" is 2019.