To claim tax benefits under an Avoidance of Double Tax Agreement (DTA) or a Limited Treaty, Singapore tax resident companies can apply for a Certificate of Residence or seek IRAS’ certification of a tax reclaim form.
On this page:The Certificate of Residence (COR) is a letter issued by IRAS to certify that the company is a tax resident of Singapore (i.e. the control and management of its business is exercised in Singapore) for the purpose of claiming tax benefits under the DTAs or Limited Treaties.
Generally, income derived by a Singapore tax resident company from foreign persons or companies may be subject to tax in that foreign jurisdiction.
Under the DTAs or Limited Treaties that Singapore has concluded with foreign jurisdictions (i.e. DTA partners), Singapore tax residents may enjoy tax benefits (e.g. tax exemptions or lower withholding tax rates) on income derived from the foreign jurisdictions. Non-residents do not enjoy these benefits.
To enjoy such tax benefits, the COR is required by and must be submitted to the tax authority of the DTA partners to prove that the company is a Singapore tax resident.
For DTAs with Limitation of Relief provisions, the Singapore tax resident company must meet an additional condition to claim DTA benefits (i.e. it must remit or will remit to Singapore the foreign-sourced income that is taxable in Singapore on a remittance basis).
ABC Pte Ltd is a Singapore tax resident company. It received royalty income from Company XYZ, who is a tax resident of Australia, and is subject to withholding tax at 30% in Australia.
However, if ABC Pte Ltd submits the COR to the Australia tax authority, it can enjoy a lower withholding tax rate of 10% on the royalty income under the Singapore-Australia DTA.
If you are not claiming benefits under the DTA but wish to obtain a letter certifying that the company is a tax resident of Singapore, you may write to IRAS using the company's letterhead with the following information:
To obtain a Certificate of Residence (COR), a company must be a tax resident of Singapore. Generally, foreign-owned investment holding companies, nominee companies and non-Singapore incorporated companies are not eligible for a COR.
Foreign-owned investment holding companies with purely passive sources of income and receiving only foreign-sourced income are not eligible for a COR. A foreign-owned company is a company where 50% or more of its shares are held by:
The ownership is applied at the ultimate holding company level.
However, IRAS may still issue a COR if these companies can show that:
This includes demonstrating that decisions on strategic matters are made in Singapore (e.g. by showing IRAS that their Board of Directors' meetings are held in Singapore). The company must also:
[NEW!] For COR applications in respect of calendar year 2025 and after , apart from demonstrating that decisions on strategic matters are made in Singapore, the company must also:
The above change is to allow these companies to better substantiate that they have valid reasons for setting up operations in Singapore.
Nominee companies are not eligible for a COR as they are not the beneficial owner of the income derived from the DTA partner. A nominee company is a company that acts as a custodian of shares on behalf of the beneficial owners.
Non-Singapore incorporated companies are not eligible for a COR as these companies are not controlled or managed in Singapore. This also applies to Singapore branches of foreign companies, as they are controlled and managed by their overseas parent company.
However, in exceptional situations, IRAS may still issue a COR if these companies can show that:
IRAS may request for additional information on the company.
For tax purposes, a VCC incorporated under the Variable Capital Companies Act 2018 is treated as a company.
To obtain a COR, a VCC must be a tax resident of Singapore. The tax residence of a VCC’s sub-funds is determined at the umbrella level of the VCC. To obtain a COR for its sub-fund, the VCC, and not the sub-fund, has to apply for the COR. The COR will show the details (tax reference number and name) of the VCC and sub-fund.
All Certificate of Residence (COR) applications have to be filed via mytax.iras.gov.sg, except for specific circumstances.
You can apply for a COR via mytax.iras.gov.sg for:
For example, in the calendar year 2021, the company may apply for a COR for the calendar years 2017 to 2021.
The company may also apply for a COR for 1 advance calendar year starting from Oct of the current calendar year.
The COR is granted to the company for the calendar year only if the control and management of its business is exercised in Singapore in the specified calendar year. If the COR is granted for the calendar year 2021, it means that the company is a tax resident of Singapore throughout the calendar year 2021.
For assistance on applying for a COR, refer to these guides:
IRAS will process your application within 7 working days of receiving the application.
Once your application is processed, a digital copy of the approved COR will be made available at the View Notices/ Letters - Corporate Tax digital service at mytax.iras.gov.sg. You may print or download the approved COR.
If your company’s notice preference in the Update Notice Preferences digital service is email notifications, you will receive an email notification within 1-3 working days that the digital COR is available at mytax.iras.gov.sg. No paper COR will be sent if your company is on email notifications.
If your company’s notice preference in the Update Notice Preferences digital service is paper notices, you will receive the paper COR at your company’s registered address within 4 working days.
Learn how to update your company’s notice preference.
This is only applicable to companies that are:
These companies may write to IRAS via myTax Mail with the following details:
IRAS will process your application within 14 working days from the day complete information is received. The processing time may be longer if the case is complex.
Once your application is processed, a digital copy of the approved COR will be made available at the View Notices/ Letters - Corporate Tax digital service at mytax.iras.gov.sg. You may print or download the approved COR.
If your company’s notice preference in the Update Notice Preferences digital service is email notifications, you will receive an email notification within 1-3 working days that the digital COR is available at mytax.iras.gov.sg. No paper COR will be sent if your company is on email notifications.
If your company’s notice preference in the Update Notice Preferences digital service is paper notices, you will receive the paper COR at your company’s registered address within 4 working days.
Learn how to update your company’s notice preference.
| Document Search Fees | Fee for Each Page of Document |
|---|---|
| $20.00 | Per certified copy $3.00 |
A Singapore tax resident company applying for DTA benefits under the DTA with a DTA partner may be required to complete and submit a tax reclaim form issued by the DTA partner with or in place of a Certificate of Residence (COR).
The tax reclaim form may require IRAS’ certification that certain conditions, such as Singapore tax residency status, are met before it can be submitted to the foreign tax authority for claiming DTA benefits.
After completing the tax reclaim form, forward the original signed form (i.e. not a photocopy) to IRAS at the following address:
Inland Revenue Authority of Singapore
55 Newton Road
Revenue House
Singapore 307987
Companies forwarding the tax reclaim form for IRAS' certification must ensure that the tax reclaim form is duly completed and signed.
IRAS cannot certify incomplete forms. Examples of incomplete forms include:
Companies who submit incomplete forms have to re-submit duly completed forms if they wish to obtain IRAS’ certification.
IRAS will process the tax reclaim form within 1 month of receiving the duly completed and signed form. In most cases, IRAS processes the tax reclaim form within 2 weeks of receiving the duly completed and signed form.
The certified tax reclaim form and a cover letter will be mailed to the company’s registered address after the application is processed. A duplicate copy of the cover letter will be made available at the View Notices/ Letters - Corporate Tax digital service at mytax.iras.gov.sg.
