Purpose and scope
The ninth edition of 30 January 2026 addresses Singapore-incorporated, GST-registered logistics companies managing goods for overseas principals using Singapore as a logistics hub. Approval suspends import GST and permits specified local movements of imported goods without GST payment. It does not excuse tax on every logistics service or every local sale. Eligibility paragraph 4.1, logistics descriptions and undertaking/control appendices, inventory-record duty, prescribed application requirements, continuing ASK requirement and deregistration requirements expressly have legal force.
Three permitted import routes
Suspension covers your own goods imported for business; goods imported as section 33(2) agent for an overseas principal for local sale or export; and goods imported as section 33A agent for re-export without a subsequent supply. The overseas principal must be unregistered or registered only as an OVR pay-only person. The same qualifying goods can be removed from a Zero-GST warehouse with import GST suspended. Other people’s goods outside these agency routes, and non-business imports, are excluded.
Specified local recipients
Imported goods can be supplied locally without charging GST only to recipients approved under MES, AISS, ACMT or Approved 3PL. Ordinary local recipients remain subject to the prevailing rate. Goods sold and delivered abroad may be zero-rated with export proof. Overseas ownership or an overseas invoice alone does not make a Singapore delivery an export.
Business and agency eligibility
The applicant’s primary business must be freight forwarding, transport or warehousing. It needs an arrangement to import and supply an eligible overseas principal’s goods as section 33(2) agent, including local supplies to specified recipients. A company with no such local supplies should not apply; MES may be more appropriate where goods are mostly exported. The principal must not belong in Singapore, meaning it has no Singapore business or fixed establishment.
Logistics management services
At least one qualifying management service must be provided without changing the original goods’ nature: inventory/procurement and sourcing, consolidation or deconsolidation, order processing, assembly/configuration/software loading, quality checks, packing/repacking and labelling, kitting/pick-and-pack, returns and repairs, or invoicing. Container stuffing/unstuffing is consolidation; low-stock replenishment is procurement; assembly can follow customer specifications, select accessories or undertake simple blending of soft commodities/liquid chemicals. Testing follows prescribed procedures. Kitting can pack factory components or finished products. Repairs can include temporary replacement, simple repair or factory return; invoices may be generated from the principal’s EDI instructions.
More-than-50% qualifying threshold
Local goods supplies to specified recipients plus zero-rated exports/international services, including your principals’ supplies, must exceed 50% of total standard-rated, zero-rated and exempt supplies. Use the immediate past financial year or any continuous 12 months within the past 18 calendar months. Remove customer-accounted purchases, reverse-charged imported services/LVG and third-party remote services/LVG reported as marketplace operator or redeliverer from the denominator. Your own direct LVG sales remain included. A business not yet trading with specified recipients must project the next 12 months’ local supplies and explain its assumptions in GST F15. Exactly 50% is insufficient.
The two numerical threshold examples
For calendar 2022 the example has ordinary standard-rated supplies S$680,680, qualifying goods S$2m, customer-accounted purchases S$20,000, reverse-charge services S$380,640, zero-rated supplies S$8m and exempt supplies S$119,320. Box 1 totals S$3,081,320 and all supplies S$11,200,640; S$10m divided by S$10.8m is 92.6%. For July 2022–June 2023, qualifying goods become S$3m, customer accounting S$120,000, reverse charge S$380,640, third-party redelivered LVG S$860,500, own LVG S$240,000, zero-rated S$6m and exempt S$809,320. Box 1 is S$5,281,820 and all supplies S$12,091,140; S$9m divided by S$10.73m is 83.9%. Both examples assume no electronic marketplace. Appendix headings in the contents mention 2020, but the actual examples and operative headings use the 2023 LVG change.
Warehouse system and control standards
A computerised WMS must identify quantity, description/identity, location and value where available for each customer or principal at any time. It must separately report receipts, exports/re-exports, local deliveries, work in progress for non-transformative value-added work and remaining stocks. Document how inventory/financial data enters GST reporting. Maintain good GST, income-tax, property-tax and Customs compliance, timely filings/payment and no major Customs violations. Accept further conditions or a required guarantee.
Agency duties and separation of records
Obtain authority to handle imports and sales and retain control while the goods are in Singapore. Treat section 33(2) imports and subsequent sales as your own for GST reporting, although the principal retains ownership. Keep each principal’s transactions and stock reconciliation separate. Charge GST on ordinary local sales, retain export evidence for exports, and reconcile each warehouse balance to imported and supplied quantities. Approval does not remove these agency responsibilities.
Goods transferred between overseas owners
Where overseas A sells goods in Singapore to overseas B and instructs delivery to B’s local section 33(2) agent, A’s local agent is treated as making a local supply to B’s agent. Without 3PL approval the import/removal and local supply attract normal GST. With approval, import GST is suspended and a transfer to another Approved 3PL or other specified recipient need not bear GST; a transfer to an ordinary non-specified local agent still bears GST. The overseas-to-overseas sale does not override the destination and recipient tests.
Application documents and review
Submit GST F15 and its requested information; a detailed narrative and diagrams of principal/customer relationships and goods movements; available contracts defining service scope and responsibilities; threshold calculations; the prescribed undertaking; latest audited accounts; and certified ASK review/error-disclosure declaration unless applying for ACAP. A valid ACAP business can perform PAR and submit F28 or apply to renew with F29. If not renewing ACAP, perform a second PAR and submit certified F28A. ASK certification and second-PAR performance/certification require an SCTP Accredited Tax Practitioner or Advisor (GST). The guide states an outcome within one month of receipt. Approval includes eligibility conditions plus any individual letter conditions.
Undertaking and goods audit trail
Sign the prescribed undertaking with applicant name/GST number, authorised signatory’s name, designation, signature, date and company stamp. Retain principal-authorisation letters. Each inward record needs receipt/import/ZG-removal date, value, description and quantity; each outward record needs date, purpose, description, value and quantity. Record handing-over/receiving persons and warehouse locations, full stocktakes/audits and receipt/removal/post-stocktake discrepancy reconciliations. Keep principals’ statutory records under GST Act section 46.
Supporting documents and discrepancies
Keep GRNs, acknowledged delivery orders, import/ME/MC/transhipment permits and AEC Inward Summary Reports, bills of lading/air waybills, available commercial invoices/insurance and principal correspondence. Outward files also need customer POs, export permits, written local-delivery/export instructions, invoices and payment evidence where received. Principal/supplier/customer identity and goods/value must be verifiable. Produce records to IRAS on request. If receipts cannot reconcile with removals and closing stock, notify IRAS within 30 days of discovery, quantify and justify the difference, and account for its GST.
Direct imports and warehouse reporting
For direct FTZ-to-customs-territory imports under the scheme, report the permit value in Boxes 5 and 9, with no Box 7 input credit because no GST was paid. Customs territory excludes FTZ. When goods first enter a ZG warehouse, report import value in Box 5 only; subsequent removal into customs territory under the scheme is reported in Boxes 5 and 9 at the removal-permit value. Both stages require valid permits and supporting commercial/shipping records. These obligations include eligible own and agency goods.
Local recipients and invoice requirements
A qualifying local goods supply is reported by the supplier in Box 1 at sales value, with no output tax in Box 6. Principal-owned goods use the principal’s customer sales invoice value. Maintain delivery/receipt proof and invoices. The recipient reports purchases in Boxes 5 and 9, based on the agent’s and/or principal’s invoice, with no input tax in Box 7. Notify recipients of these reporting duties. The invoice must state that GST payment is not required under the Approved Third Party Logistics Company Scheme and need not show a GST amount. This is not a Box 2 zero-rated export.
Ordinary local sales and exports
Local sales to non-specified recipients go into Box 1 and the GST into Box 6. Export sales go into Box 2 only where supporting export proof exists, using principal invoices where applicable. Section 33A re-export without a subsequent sale is also reported as a zero-rated supply in Box 2 with export proof under this guide. Ordinary logistics-service invoices require their own normal GST analysis; suspension of goods taxes does not itself zero-rate the service.
Permit errors and tax actually paid
If an ME permit overstates or understates value, report the correct imports in Boxes 5 and 9 rather than the erroneous amount. No additional permit is needed solely to declare the shortfall under this appendix, but keep valid permits, invoices/shipping evidence and a reconciliation explaining the correct return figure. If a GST payment permit was wrongly taken instead of an ME/MC permit, report purchases in Box 5 and claim the tax actually paid in Box 7 only if normal input conditions are met; retain that import permit.
TradeNet and appointed agents
Activate the Customs account and subscribe to TradeNet to use relevant ME permits for non-dutiable imports or ZG removal. Up to 20 third-party declaring agents can be authorised and updated through myTax Portal’s Apply for Declaring Agents service, accessed by a Corppass-authorised GST Tax Matters preparer/approver. Maintain the list yourself. FedEx, UPS and DHL Express are automatically permitted to act as declaring agents and need no separate appointment.
Express-company reports and misuse controls
Use AEC monthly Inward Summary Reports or subsidiary import certificates to report imports. To stop an AEC using scheme status, notify it in writing; it then pays GST using payment permits and seeks reimbursement, potentially recoverable under normal input rules. Keep AEC contact/email records current. Instruct overseas shippers to identify the rightful importer as sold-to/bill-to, not the handling agent for a local customer. Periodically reconcile all permits from agents, AEC reports and TradeNet against purchase/import records. Notify incorrect declarations promptly and arrange correct-importer replacement permits. Partially exempt businesses failing de minimis cannot use status for imports unrelated to taxable supplies or directly attributable to exempt supplies.
Guarantees and continuing approval
IRAS may require a guarantee, setting its amount and validity. It accepts Singapore banks/insurers, including local branches of foreign institutions. eGuarantees from participating institutions replace physical courier delivery; the guide describes lodgement falling from seven days to one. Approval remains valid while eligibility and responsibilities are met, including certified ASK annual review. ACAP status reduces routine GST compliance work during its tenure unless significant declaration anomalies arise. Periodic IRAS audits remain possible.
Changes, transfer and termination
Notify the Comptroller immediately of material business/principal/customer changes that remove eligibility, including cessation of supplies to specified persons; approval terminates when eligibility ends. Status cannot transfer with a going concern: the new owner must apply in its own name, and the former owner should terminate if no longer eligible. False or misleading eligibility information or breached requirements can lead to written revocation.
Repayment and deregistration
Misused suspension for imports or ZG removals outside the permitted scenarios must be repaid and reported as output tax in Box 6. Incorrectly untaxed local supplies to non-specified recipients require repayment of the GST chargeable; incorrect returns can attract penalties. On GST deregistration, own suspended-import goods form part of taxable stocks/assets: if the total on hand exceeds S$10,000, account for deemed output tax in the final return under normal deregistration rules. Overseas-principal section 33(2)/33A goods follow the separate Guide on Imports agency-deregistration rules.
Edition history and terminology cautions
The guide began in August 2015. Later changes cover declaring-agent access, continuing ASK reviews, OVR pay-only principals from 2020, SCTP naming, the 2023 remote-service/LVG extension, digital guarantees in 2023 and AEC/control updates in January 2026. Some 2026 operational wording and Appendix 9 refer to MES status although this is the Approved 3PL guide; apply the stated controls to this scheme rather than assuming a separate MES approval. Enquiries should be directed through IRAS Contact Us to its GST Division.
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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