Approved Marine Fuel Trader Scheme: Eligibility, GST Returns and Record Controls: Eligibility, GST Returns and Record Controls

Edition, commencement and purpose

This seventeen-page sixth edition was published on 30 January 2026. Earlier editions appeared in December 2004, March 2005, October 2007, September 2013 and December 2022. Introduced on 1 January 2005, AMFT eases an approved bunker trader’s cash flow by removing upfront GST payment on specified local marine-fuel purchases. Approval is normally valid for three years, but the Comptroller can grant a shorter period.

Only marine fuel oil receives the purchasing treatment

Eligible marine fuel oil, or MFO, is used in ocean-going vessel engines, for example MFO 380cSt. Marine diesel oil, marine gas oil and LNG are excluded from the purchase relief. The guide refers to Singapore bunkering standards SS 648 and SS 600 and marine-fuel quality under ISO 8217. A disputed classification may be referred to MPA or qualified surveyors under the latest applicable standards. Do not infer eligibility from the general description bunker fuel alone.

Local purchases and imports are different

An approved buyer can purchase MFO from a GST-registered supplier without paying GST. The supplier need not itself be AMFT-approved; the buyer’s status determines this local treatment. Tell suppliers the approved status and ensure invoices show no GST amount and state that GST payment is not required under AMFT. Imported MFO still attracts import GST unless a separate import-suspension scheme, such as MES, applies. AMFT does not by itself suspend customs GST.

All qualifying criteria and legal status

The guide explicitly gives its section 6 conditions legal force. The business must be incorporated or registered in Singapore; primarily supply bunker fuel for ocean-going ships; have begun supplying MFO; and hold a valid MPA bunkering licence with at least three months remaining at application. As general guidance, bunker-fuel sales must be at least 50% of total sales over twelve months.

It must also be GST-registered, with good customs/excise, income-tax, property-tax and GST compliance and payment records; maintain good internal controls, accounting and records; comply with scheme conditions; and accept full GST responsibility if approved conditions later fail. The Comptroller may vary or add requirements and may require security on grant or renewal, notified in writing.

Application form and all supporting documents

Submit GST F16 with a concise description of the business, main products and major MFO suppliers and buyers; a copy of the MPA bunker-supplier licence permitting MFO; and the latest audited financial statements. A licence only for MGO or LNG, or a bunker-craft operator licence, is not accepted.

If the latest financial year is not yet audited, supply the most recent audited statements and an external-auditor letter giving the expected completion date and explaining any delay. Businesses trading MFO for less than twelve months must project twelve months of MFO purchases, bunker-fuel sales including MFO/MDO/MGO/LNG, and total revenue from commencement, explaining the basis with contracts or agreements. The guide says applicants are notified within one month after complete information is received, not one month after an incomplete application.

Continuing responsibilities and notification duties

Section 8 requirements also have legal force. Give MFO suppliers the approval letter showing its validity. Keep separately identifiable MFO purchase and sales records and produce them on request. Follow the prescribed accounting and record controls. Immediately tell suppliers when aware AMFT will be revoked or not renewed, and tell the Comptroller when the bunkering licence will be revoked or not renewed. Continuing to buy under an expired or lost status is not justified by an old approval letter.

Invoices, delivery and payment evidence

Retain supplier tax invoices without a GST amount and with the AMFT annotation, delivery orders acknowledged on receipt, payment evidence and marine-surveyor certification where relevant. For sales to another approved buyer, issue an annotated tax invoice too. The mandatory notation identifies the specific scheme treatment; an ordinary zero-rated invoice does not describe the same transaction.

Both parties’ GST return boxes

The supplier reports the local sale value, in S$ from the invoice, as standard-rated supplies in Box 1, without corresponding Box 6 output tax under the scheme. The approved buyer reports S$ purchase value in Box 5, without Box 7 input tax because none was paid. Apply time-of-supply rules. This is still a standard-rated local supply with the scheme removing payment, not an export to be entered as zero-rated simply because the invoice has no tax.

Non-compliance: repayment without matching input credit

Non-compliance includes losing qualification, such as a revoked licence, while remaining in the scheme without notifying IRAS, or breaching imposed conditions. The buyer must repay GST the supplier did not charge because of that non-compliance, declaring it as output tax in Box 6. No corresponding input claim is allowed: the payment arises solely from the buyer’s breach.

The footnote distinguishes a supplier’s own omission where there is no reasonable basis to attribute it to the buyer’s scheme non-compliance. That is not automatically the same buyer-repayment case. Separately, unexplained quantity or type discrepancies can require the buyer and supplier to account for GST, subject to audit findings.

Validity, renewal and GST deregistration

Seek renewal approval at least three months before expiry to continue immediately after the previous approval ends. IRAS can revoke without advance notice for breached conditions, lost qualification or false, misleading or inaccurate application information. On GST deregistration, follow ordinary deregistration requirements: remaining goods bought under AMFT or other GST-suspension schemes can form assets or stock on which output tax is accountable where applicable, even though GST was not paid on purchase.

Group members, overseas principals and supplier duties

GST group registration uses one representative member to file a group return, but AMFT is granted only to the qualifying member, not every group company. An approved person joining a group keeps its own status. A section 33(1) agent’s overseas principal cannot use the agent’s approval to buy locally without GST. Suppliers otherwise have the normal GST obligations, including the invoice and return treatment described above; the scheme is not an approval of every customer in the group.

Appendix 1: both complete supply chains

In chain A, approved trader A or non-approved trader B supplies approved C: both local sales can avoid GST payment under AMFT. Imports by either seller remain subject to import GST unless a separate scheme applies. C’s direct delivery aboard a foreign-bound ship or export may be zero-rated with proper export evidence.

In chain B, the same sellers supply non-approved C: both must charge and account for local GST at the prevailing rate, regardless of the seller’s own approval. C’s subsequent qualifying export may still be zero-rated. These chains show why seller approval, buyer approval and export status are three different questions.

Appendix 2: inventory and internal controls

Track each MFO sale to its approved buyer and each purchase in an inventory system. Be able to evidence quantities and values for all MFO transactions and separately those without GST payment. Conduct a complete stocktake or inventory audit at least annually where applicable, with reconciliation reports for every discrepancy. On request, produce appropriate certification from a licensed bunker surveyor who sampled inventory or sales.

Appendix 2: all record categories

For every purchase and sale keep purchase orders, payment or collection evidence, buyer-acknowledged delivery orders, relevant surveyor certificates and supplier invoices. Reconcile both value and quantity and distinguish scheme purchases and sales from all other taxable transactions. Produce records readily on request and retain business records for at least five years. Electronic records need no prior GST approval, but must comply with the GST-registered-business record-keeping guide. The appendix also repeats return boxes, invoice wording, discrepancy responsibility and deregistration treatment explained above.

Appendix 3: the complete 50% test

Record applicant name, UEN and the same twelve-month period used in GST F16 section 2.2. The example has S$2,000,000 bunker-fuel sales plus S$690,680 other revenue, such as rent or interest, giving total revenue S$2,690,680. The ratio is 2,000,000 ÷ 2,690,680 = 74.33%, satisfying the at-least-50% criterion.

For this eligibility calculation only, bunker-fuel sales include MFO, MDO, MGO and LNG, including sales as principal for the business and in the capacity of a section 33(2) local agent for an overseas principal. That inclusion does not make MDO/MGO/LNG eligible for GST-free upfront purchases. Nor does the section 33(2) threshold reference override the separate FAQ denying an overseas principal use of a section 33(1) agent’s approval.

Ten FAQs, revision history and enquiries

All ten FAQs are covered by the record-retention, seller and buyer return boxes, validity, deregistration, renewal, supplier duties, group members, overseas-principal and invoice sections above. The December 2022 revision updated bunkering standards, customs compliance, records and invoice explanations and removed the old letter-of-guarantee appendix; security is now notified if required. This article uses the January 2026 sixth edition and preserves all three appendices. Questions go to the GST Division through IRAS Contact Us, with the original source linked.