Purpose and source edition
The eighth edition published 18 March 2026 explains the Approved Contract Manufacturer and Trader scheme for GST-registered contract manufacturers, especially semiconductors, printing and biomedical manufacturing. Normally, processing a client’s goods that remain in Singapore attracts GST, which an unregistered overseas client may not recover. ACMT can disregard qualifying processing fees and provide defined import-suspension and input-recovery benefits. This is a specific contractual and goods-flow arrangement, not a blanket exemption for overseas-client work.
Manufacturers, logistics companies and overseas clients
ACMT CM processes goods for its overseas client and then delivers locally or exports as instructed. ACMT LOG receives processed goods from that client’s CM and distributes them to another CM or the client’s customers. A LOG cannot receive from or deliver to another LOG and has no ACMT tax privileges of its own. An eligible overseas client belongs outside Singapore and is unregistered, or only OVR pay-only registered; a client operating a GST-registered Singapore branch or similar establishment counts as registered. Check the published approved-persons list for CM/LOG status.
What counts as value-added activity
Qualifying activities are processes applied to goods under a contract with, and directly benefiting, the same overseas client. Manufacturing, processing, assembly, quality control and functional testing may qualify under consignment, modified-turnkey or full-turnkey arrangements. Distribution and logistics services are excluded. Processed goods are goods value-added under that qualifying contract; the fees and the eventual goods transaction require separate GST analysis.
The five import-suspension scenarios
A CM may suspend import GST for its own business goods; section 33(2) goods for local supply/export; section 33A goods for subsequent re-export; and section 33B re-imports of goods previously sent abroad for value-added work for local or normally GST-registered overseas customers, excluding OVR pay-only customers in this fourth route. The fifth route covers overseas-client consigned goods processed for that same client and subsequently exported, delivered to another CM/LOG or its customers, or, for failed/excess goods, destroyed/disposed of by the CM or an appointed vendor. Section 33(2)/33A principals must be unregistered or OVR pay-only. Where goods change form, the section 33(2) agent must still track them and ensure all imported goods are supplied.
Disregarded processing fees and final goods
Qualifying value-added fees can be disregarded where goods are exported or delivered to another CM/LOG or the overseas client’s customers. Retain export proof for goods leaving Singapore. For local delivery to the client’s actual customer, the CM must account for GST on the overseas client’s actual goods sales value, even though the separate processing fee is disregarded. Disregarded processing fees are not reported in GST returns; exports of goods are reported as zero-rated goods supplies.
Failed and excess production
Relief also covers inherently failed or excess output arising from the overall manufacturing engagement. Failed output has unsatisfactory quality; excess output exceeds the client’s required quantity. It can be exported with evidence or sent directly, or through a LOG, to a waste vendor for local destruction/disposal without consideration, supported by a scrap or destruction certificate. If the CM disposes of goods itself, seek the Comptroller’s confirmation with process and document details. Local scrap proceeds attract GST on the consideration received on the client’s behalf. Input tax attributable to disregarded activities remains recoverable subject to GST Act sections 19 and 20.
Recovering GST on the client’s local purchases
A CM may claim GST on local goods bought by its overseas client from a GST-registered supplier and delivered to the CM as inputs for the same client’s processing, including raw materials and semi-finished goods. The final goods must follow the approved export, delivery or failed/excess-disposal routes. Crucially, the CM must bear the tax: either pay it without seeking reimbursement from the client, or refund tax the client paid, outright or by offset against processing fees. Keep payment/refund evidence. Inputs not used in that processing are not recoverable under this privilege.
Invoices, timing and a CM’s own goods sale
The local supplier’s tax invoice must be addressed to the overseas client, the contractual buyer, not the CM. Retain its copy and the CM-endorsed delivery order. Claim in the invoice-date accounting period, or consistently use a later posting date with controls against double claims. If the CM itself separately sells raw materials locally to the client, it must invoice and account for GST normally; it may also recover that tax as the client’s agent where the goods are consigned back to it for qualifying processing and it bears the tax under the same conditions.
CM commercial eligibility
The CM must be GST-registered, with annual turnover at least S$10 million, in semiconductors, printing or active pharmaceutical ingredient manufacturing. Other biomedical segments or industries can request case-by-case consideration with reasons, contracts and arrangements. Mutual shareholdings with the overseas client must not exceed 50% unless specifically approved. Overseas-client value-added contracts must represent at least 51% of annual turnover; the Comptroller also considers substantial contracts of at least S$1 million. Past records or a supported 12-month forecast from application can be used, including an imminent contract evidenced though not yet signed.
Export tests and the annual review
CM eligibility requires at least 85% of goods processed for overseas clients to be exported. For the individual disregarded arrangement, the responsibility section/checklist states either at least 85% export by the CM, or 100% delivery to another approved CM/LOG appointed by the same client, with failed/excess goods disposed of properly. These arrangement checks do not erase the separate overall eligibility condition. Review annually, confirm recipients’ current approval and tell them goods are delivered under ACMT. New arrangements should pass all seven Annex C checks: client status, relationship, qualifying contract/direct benefit, export/approved-transfer route, local sales tax, disposal evidence and inventory controls.
Inventory qualification and biomedical certification
Track consigned receipts, work in progress, local/export deliveries, failures/excess within client-agreed tolerance and remaining stock at all times. Semiconductor/printing applicants use Annex B and the CM Pre-Application Checklist, and may receive a site visit. Biomedical businesses with PIC/S-standard or equivalent GMP certification incorporating comparable inventory controls satisfy the stated control condition; attach a valid certificate and/or HSA manufacturer-licence auto-renewal notification. Without that certification use applicable Annex B controls and checklist and expect possible site review.
Recipient accounting is a separate event
A CM receiving processed goods from another CM/LOG, and a LOG receiving them from a CM, must perform recipient accounting on receipt. Treat the receipt as a local business supply, account for output tax and claim the same tax as input. Use market value, or if unavailable/unknown a nominal S$1 multiplied by the number of goods received. Report the value in Boxes 1 and 5 and tax in Boxes 6 and 7. This receipt calculation does not replace tax on a later actual customer sale.
Distribution, tax point and overseas registration
As distributor, a CM/LOG accounts for local goods GST using the client’s actual customer sale value at the earliest of delivery, issue of a relevant invoice or payment receipt. Exports require evidence and Box 2 reporting; local scrap proceeds are taxable. Goods supplies handled under ACMT are excluded in determining the overseas client’s registration threshold only where its appointed CM/LOG accounts for their GST. The client need not register if its other taxable supplies do not exceed S$1 million annually, subject also to the separately applicable OVR rules. Logistics-service fees continue under normal GST rules.
Distinguishing customers from unauthorised recipients
The source explicitly permits final delivery to the overseas client’s actual customer with GST on sales value and disregarded processing fees. It separately treats an unauthorised non-ACMT recipient, such as the client’s local related entity outside that customer-sale route, as a deemed goods supply taxed at market value plus normally taxable processing fees. Paragraphs 6.4 and 15.1(b) phrase non-ACMT delivery broadly, whereas paragraph 4.2 and Annex D explicitly retain the final-customer route. Read them together, document the recipient’s role and seek IRAS clarification if the arrangement cannot clearly be placed in the permitted customer-sale route.
CM return mapping for imports and onward movements
Consigned imports are Boxes 5/9 with suspended GST. Eligible local inputs bought by the client are Boxes 5/7. Receipt from another approved person is Boxes 1/5/6/7 through recipient accounting. Exports are Box 2; final local customer sales are Boxes 1/6 at actual sales value. Transfers to another approved CM/LOG require no reporting of outgoing goods by the sender, since the recipient accounts on receipt. Unauthorised non-ACMT transfers use market value in Boxes 1/6 and processing fees also go into Boxes 1/6. Eligible disregarded fees need no return entry. Scrap sold for consideration is Boxes 1/6.
CM control standards: receipt and production
Maintain records of raw materials received, WIP, spoilage/material-store balance, exports, approved-recipient deliveries, customer deliveries, unauthorised deliveries and failed/excess disposal. All receipts, replacements and returns need GRNs, acknowledged delivery orders and Material Quality Rejects or equivalent records. Issue materials only against authorised Material Requisition Forms based on Manufacturing Orders, or controlled equivalents. MOs track material description/quantity and completed/planned stages. These records connect goods ownership and movement to the production process.
CM control standards: delivery and recovery proof
For client-purchase recovery retain supplier-to-client tax invoices, CM-endorsed delivery orders and evidence of payment/refund of tax; fee offsets must appear clearly in invoices/accounts. Export invoices, permits, packing lists and delivery orders must trace to client purchase orders and Bills of Materials showing input types/quantities. Records must identify exported finished goods and embedded consigned materials. Local deliveries need recipient identity/quantity, acknowledged delivery proof and the CM’s tax invoice charging on the client’s sale. Disposal needs vendor certificates and available disposal-service invoices.
Stocktakes, reconciliation and external audits
CMs must conduct full internal stocktakes/inventory audits at least annually, immediately report discrepancies beyond agreed tolerance and explain them. Periodic client reconciliations identify deliveries, custody balance and recipients/quantities, potentially endorsed by the client’s external auditor after physical checks. IRAS may request independent audit of inventory systems/controls; report a qualified opinion within one month. Retain all records for production on request. A LOG’s discrepancy rule is stricter: report any shortfall immediately and account for output tax on market value in the period discovered.
LOG eligibility and the absence of manufacturer benefits
A LOG must be GST-registered and appointed to distribute the overseas client’s CM-processed goods to another CM or the client’s customers. Mutual shareholdings with the client must not exceed 50% unless specifically approved; at least 85% of processed goods received must be exported. Keep current inventory and accounting records, good IRAS/Customs compliance, and ASK or ACAP participation. Unlike a CM, LOG status does not itself confer import suspension, disregarded logistics fees or the client-purchase recovery privilege. Additional requirements, including a guarantee, may be imposed.
LOG movement controls
Track all CM receipts, exports, local customer deliveries, destruction/disposal, returns to CM for rework and warehouse balances. Complete a full annual inventory audit. Retain GRNs and acknowledged delivery orders for receipts; authorised shipment/delivery records and proper export proof for outward movements. Reconcile inbound, outbound and closing quantities, identify local customers and quantities through the accounting system and regularly account to the overseas client. Keep reconciliation reports and provide any requested independent audit; a qualified opinion must be notified within one month.
LOG return mapping and disposal evidence
Receipt from CM uses recipient accounting in Boxes 1/5/6/7; local final sales use Boxes 1/6 at client sale value; exports use Box 2 with proof. Transfer to another client-appointed CM is not reported by the LOG, and the CM accounts on receipt. LOG-to-LOG movements are prohibited. An unauthorised non-ACMT transfer uses market value in Boxes 1/6. Local scrap proceeds and custody shortfalls use Boxes 1/6, the latter at market value in the discovery period. Keep disposal proof and provide the client’s CM a copy where required. Logistics fees remain normally taxable or zero-rated according to their separate conditions.
Compliance review at entity or GST-group level
CM/LOG must timely file GST and income-tax returns and pay GST, income tax, property tax and withholding tax, with good Customs compliance. ASK is a self-review for accurate submissions and early error disclosure; ACAP validates a robust GST control framework. Divisional registrations must review/commit as the whole entity; group registration requires all GST-group members to complete ASK or commit to ACAP. The stated eligibility/control clauses for each role have legal force.
Application package and supply-chain illustration
A CM applies using GST F14A and its Pre-Application Checklist; a LOG uses F14B. Supply latest audited accounts with an unqualified auditor’s opinion, a description/illustration for each client contract and export proportions, and appropriate GMP/HSA evidence for biomedical applicants. Annex H’s flow identifies client and local supplier, local/overseas input types, processing services and fee basis, finished goods, appointed LOG/CM, major customer names, local/export proportions and disposal evidence. Similar client supply chains may be consolidated into one representation. Provide any further requested documents.
ASK, ACAP and application processing
Submit an ASK declaration certified by an in-house or external SCTP Accredited Tax Practitioner/Advisor (GST), retaining Section 3 working templates. Successful ACAP applicants need not submit it unless participation is withdrawn or status fails; then undertake ASK immediately and submit a certified declaration within six months. Valid ACAP businesses may submit PAR F28 or renewal F29; those not renewing must perform a second PAR and submit F28A performed/certified by an accredited GST professional. Complete applications normally receive an outcome within one month, but extra evidence or site visits may extend processing; a guarantee may be required.
Validity, MES replacement and renewal
Initial approval lasts three years, subject to ongoing eligibility and individual approval-letter conditions. CM approval supersedes any MES status; withdrawal followed by MES application is a new application. Renewal invitations specify the deadline for the ACMT renewal self-review checklist, certified ASK declaration and certified ACMT transaction-review appendices. A clean renewal can last up to five years; ACAP holders’ ACMT status remains valid through their ACAP tenure. Eligibility failure can trigger revocation at any time.
Withdrawal and goods clearance
If ineligible, withdraw voluntarily and notify the Comptroller in writing within 30 days. Failure can lead to retrospective revocation and repayment of GST that normal rules would not have suspended, disregarded or allowed. Before withdrawal, non-renewal or revocation, fulfil all client contracts, deliver all processed goods and hold no ACMT goods. After CM termination, imports require payment permits, processing follows normal GST and client-incurred local purchase tax can no longer be recovered under ACMT.
Four deregistration categories
Own suspended-import goods attract normal final-return deemed tax if taxable stocks/assets on the last registration day exceed S$10,000. Overseas-principal goods still held from section 33(2)/33A imports require import-GST repayment under the Imports Guide. For section 33B goods, make the taxable value-added supply before deregistration or repay re-import GST. For ACMT-consigned/local-input and processed goods, complete processing and export/delivery with applicable GST before the deregistration application can be considered: no ACMT goods may remain.
Repayment, corrections and penalties
Wrong suspension must be repaid without demand as output tax in the original import period, with no input claim for that repayment. Incorrectly disregarded fees follow normal output-tax rules, including ineligible registered/related clients or unauthorised recipient arrangements. Missing GST on customer sales uses actual client sale value; unauthorised non-ACMT movements use market value and may additionally require processing-fee and import-tax repayment. A claim made without bearing the client’s purchase GST is repaid in the claim period. Correct already-filed periods using GST F7, subject to the separate error-correction administrative concession. Penalties and revocation can apply.
Current permit procedures and express-company controls
The March 2026 change specifies ME/MC permits, TradeNet message IN-Non-Payment, declaration APS—Approved Premise/Scheme and Place of Receipt code ME for direct imports. Up to 20 declaring agents can be maintained through myTax Portal by a Corppass-authorised GST Tax Matters preparer/approver. FedEx, UPS and DHL Express need no separate appointment. Use their monthly Inward Summary Reports/subsidiary import certificates for return figures. Written opt-out means payment permits and reimbursement, with recovery only under normal input conditions. The CM remains responsible for every permit using its status and must control appointments and misuse.
Edition history and enquiries
The first edition was July 2018. October 2019 accommodated OVR pay-only clients; March 2021 adopted the SCTP name; August 2022 updated OVR’s extended scope; January 2023/2024 were editorial updates. January 2026 clarified automatic AEC agents and ACAP non-renewal requirements, and March 2026 clarified import-permit procedures. Read the stated dates with the applicable transaction period. Enquiries on arrangements and the guide go to IRAS’ GST Division via Contact Us.
Official source
This article independently explains the substantive contents of the official PDF, including the relevant conditions, procedures and annexes. The linked document remains the authoritative source for its original wording, and later changes should be checked separately.
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