Scope and service location
The chart concerns management services or assistance in managing a business from 29 December 2009, including routine support services in the cited transfer-pricing annex. First ask whether services are performed outside Singapore. A yes leads to no withholding tax in this chart; a no leads to the next test. The recipient’s overseas address alone is not the same as performing the service overseas.
The historical cost-pooling route
A related-party cost reimbursement under a qualifying cost-pooling arrangement, liable to be paid on or before 31 October 2022, follows the chart’s no-withholding branch. The date qualifies that branch; it cannot simply be extended to every later reimbursement. The footnote refers to the source edition’s transfer-pricing paragraph and page numbers, which should not be treated as permanent numbering in all newer editions.
Treaty residency and the PE condition
If that route does not apply, ask whether the recipient is resident in a country or territory with a comprehensive DTA. Without one, withholding applies. With one, ask whether the treaty requires a permanent establishment for the income to be taxable in Singapore. If it does, withholding applies where such a PE exists, and not where it does not. If the treaty does not require a PE for that income, the chart leads to withholding. Read the actual income article rather than assume every treaty uses the same test.
The footnote’s treaty changes
The footnote lists Australia, Pakistan, the Republic of Korea, Sweden and Taiwan as examples but qualifies the Australia and Korea entries. From 1 May 2018, Singapore services through personnel of a non-individual Australian tax resident are treated as enterprise profits, taxable in Singapore only where they constitute a treaty PE. The Korea exception refers to the 1979 treaty; the revised treaty signed 13 May 2019 and effective 1 January 2020 places enterprise professional and independent services under Business Profits, again requiring a Singapore PE in that route. Do not carry those old exceptions into the revised periods.
Evidence for the selected branch
Keep the service contract, place-of-performance records, related-party reimbursement basis and payment-liability date, treaty-residency evidence and PE analysis. The chart decides whether withholding applies in its described circumstances; it does not print a universal tax rate or complete filing procedure.
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 ↗