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Taxes · PDF

Telecommunication GST: International Transmission and Zero-rating

The twenty-two-page guide explains section 21(3)(q), all six Fifth Schedule paragraphs and fifteen scenarios, with two annexes. Zero-rating requires a prescribed service under paragraphs 1–5 and international transmission. The customer’s Singapore or overseas belonging status does not determine this particular relief.

Source checked · 11 October 2026 · Document date: 30 Jan 2026

Scope of the January 2026 second edition

The twenty-two-page guide explains section 21(3)(q), all six Fifth Schedule paragraphs and fifteen scenarios, with two annexes. Zero-rating requires a prescribed service under paragraphs 1–5 and international transmission. The customer’s Singapore or overseas belonging status does not determine this particular relief.

International endpoints and domestic routing

Qualifying transmission runs foreign-to-foreign, Singapore-to-foreign or foreign-to-Singapore. Singapore-to-Singapore remains local even if routed through HongKong before returning. Ordinary GST applies unless another international-service provision independently qualifies.

Paragraph 1: signals, not content or physical delivery

Wire, radio, optical and electromagnetic transmission of signals, images, sounds or information qualifies even if processing occurs in transit. Scenario 1 satellite uplink/downlink qualifies when international. Scenario 2 separates a S$20 game from S$1.50 download usage: only qualifying international transmission gets this relief. Scenario 3 receiving satellite signals may qualify, but copying them onto a tape and delivering that tape does not. Content and transport on tapes, cards, disks or flash drives are outside paragraph 1.

Paragraph 2: international leased capacity and both local-link conditions

International leased circuits, lines or networks qualify. A connected local leased link qualifies only when the same supplier provides both links and the local link is part of its international provision. Scenario 4 IPLC for overseas subsidiaries qualifies. Scenario 5 separate local and international suppliers leaves the local supplier’s link taxable. Scenario 6 one contract for independent local-branch and Vietnam-subsidiary links does not turn the domestic branch link into part of the international service.

Paragraph 3: access and use rights, excluding SIM goods

Registration/connection charges grant access, while subscriptions grant use of prescribed transmission or leased capacity. Scenario 7 international roaming subscription S$15 and international usage S$20 can both be zero-rated under their respective paragraphs. A SIM card remains a good even though needed to make calls, and does not qualify under paragraph 3.

Paragraph 4: resale by hotels and serviced apartments

A recipient of prescribed paragraph 1/2 services can supply another person access/use rights. Hotels and serviced apartments reselling international calls may zero-rate the price charged to guests. Separately billed administration fees/surcharges are standard-rated. The PDF retains the historical licensing reference to IDA; the article does not treat that agency name as a new licensing instruction.

Reimbursement: cost-only recovery and markup examples

A business outside telecom resale can zero-rate recovery only up to international-call costs. Scenario 8 shared office phone: recover S$100 calls at zero GST. Scenario 9 recovering S$120 including S$20 administration markup requires separate invoice lines:S$100 may be zero-rated and S$20 normally taxable unless another relief applies. If not shown separately, the whole S$120 is standard-rated. A markup remains a separate administrative service regardless of its description.

Paragraph 5: ancillary services and the five-percent measure

Ancillary services must accompany paragraph 1/2/3 services from the same supplier. Total ancillary cost under the same contract≤5 percent of total package consideration is the small-cost guide. Scenario 10 monitoring plus performance reporting costs 3 percent and can follow qualifying international transmission. This compares cost with consideration, not ancillary selling price with total cost.

Above five percent: all four additional conditions

IRAS may still accept an ancillary component where it is in the same contract, not separately priced, not supplied independently by that supplier, and customers cannot subscribe to it alone. Scenario 11 monitoring costs 6 percent but is an inseparable unpriced deliverable and not independently offered: it can qualify with international transmission. The guide describes consideration by the Comptroller, not an unconditional six-percent safe harbour.

Paragraph 6: equipment and standalone maintenance exclusions

Equipment sales and rentals are excluded even when used internationally: scenario 12 equipment lease cannot use 21(3)(q). Scenario 13 standalone maintenance on international cables fails because that supplier supplies no transmission. Scenario 14 maintenance under an international-transmission contract may qualify only if the ancillary conditions are met, despite a monthly maintenance fee. Repair, maintenance or management unrelated to international transmission is excluded.

Mixed transmission: track volumes or justify a proxy

Only the international component qualifies. Without tracking international/local volumes, standard-rate the full supply: scenario 15 general internet access to domestic and overseas websites with no split tracking fails full zero-rating. The Comptroller also accepts reasonable apportionment proxies: standalone market prices, direct/indirect costs using a suitable costing method, or time spent on each part. Preserve the method and evidence instead of assuming all internet traffic is international.

AnnexB: voice, messaging, wholesale and mobile data

Voice usage, satellite-like transmission and mobile data usage fall under paragraph 1; activation/subscription generally under paragraph 3. SMS/MMS/instant-message subscription and usage follow the same access/transmission distinction. Wholesale voice subscription is access. For these eligible lines, local transmission is standard-rated, international zero-rated, and untracked mixed traffic fully standard-rated. Termination, late payment, software, multi-SIM, phonebook backup, itemised/reissued bills, number changes and subscription transfers are outside this relief. Monetary prepaid call vouchers follow the separate voucher guide.

AnnexB: networks, broadband and ancillary support

IPVPN, IP transit, ATM, frame relay, domestic/international private circuits, Ethernet and backhaul activation/subscription use access rules; usage uses leased-capacity rules. Wholesale IPVPN/transit subscriptions follow access rules. General wired/wireless/cable/dial-up broadband, bandwidth-on-demand and speed upgrades split subscription versus usage similarly. Network monitoring/support, contact centres/performance reports, antispam/antivirus and extra email storage need the ancillary test; the annex does not grant them automatic international zero-rating.

AnnexB: push mail, satellite, content and other services

Push-mail subscriptions and usage follow access/transmission respectively. Satellite uplink/downlink is transmission; space segments, VSAT and transponder capacity follow leased-network treatment. Ringtones/screensavers/audio downloads, TV activation/subscription/pay-per-view and online games are content outside 21(3)(q), even with overseas game servers. Co-location may qualify separately under 21(3)(s), hosting/disaster recovery under 21(3)(j). Hotspot construction and GPS tracking are not prescribed under this telecom relief. AnnexA sets out the six-category statutory framework; doubts can be raised with IRAS GST Division using the original source link.

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.

Read the official PDF ↗
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