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Withholding tax
caught before you pay overseas.

Section 45 · Non-Resident Payments · S45 Filing

Pay a non-resident company or individual for royalties, interest, services, rental or director’s fees, and a slice may be owed to IRAS before the money leaves Singapore. We identify what’s dutiable and file the S45 form correctly.

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Section 45

Overview

Deducted before it leaves Singapore

Withholding tax is the amount a Singapore-based payer must deduct and remit to IRAS whenever paying a non-resident company or individual for specified services, under Section 45 of the Income Tax Act. “Non-resident” isn’t just about physical location — a company managed and controlled from abroad counts as non-resident even with a Singapore branch, and an individual needs at least 183 days in Singapore in the relevant year to count as a tax resident.

Rates by payment type

Payment typeRateNotes
Royalties / use of information or IP rights10% of gross paymentOnly where the information brings commercial benefit — not personal, educational or operational use.
Interest, loan-related fees, and rental of movable property15% of gross paymentExemptions apply for approved banks’ Singapore branches, loans for overseas property, and certain approved entities.
Management, technical and service fees17%Applies where the service is performed in Singapore; purely virtual assistance from abroad is excluded.
Purchase of real estate from a non-resident trader15%Applied to the property’s price; buyers can request proof of the seller’s trader status.
Individual professional services15%Consultants, lawyers and private practitioners who are non-resident.
Non-resident director’s remuneration24%Increased from 22%, effective 1 January 2023.
REIT distributions to non-resident unit-holders15%Withheld by the distributing REIT.

Why HeySara

Tax filing that doesn't rely on you remembering a date

1

ACRA-registered agents

Filed under FA20200042 / FA20031119 — every submission goes through IRAS’s official channels via CorpPass.
2

Deadline reminders, not surprises

We track your financial year-end, GST quarters and every trigger-based deadline, and reach out before, not after.
3

One team, full picture

The same team handling your bookkeeping prepares your tax computation, so numbers reconcile the first time.
4

Straightforward pricing

Fee guidelines published upfront, with add-ons flagged clearly before we start work — no surprise invoices.
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About to pay an overseas vendor or director?

We’ll confirm whether withholding tax applies and file S45 before the payment goes out.

FAQs

You, the payer. Withholding tax is deducted from the payment before it’s sent, and it’s the Singapore-based payer’s legal obligation to remit it to IRAS.

It can — a company is judged non-resident based on where its management and policy decisions are made, not where it has a physical branch. A Finland-headquartered company with a Singapore branch is still non-resident for this purpose.

Generally no for technical/office assistance — the 17% rate applies specifically where the non-resident’s staff perform the service physically in Singapore, not purely remote assistance.

It generally covers know-how, advisory, or hands-on assistance delivered by the non-resident’s staff — the key test is whether the work is performed physically in Singapore, which is what triggers the 17% rate.
It applies to any qualifying payment regardless of frequency — a single one-off royalty or service fee to a non-resident is just as dutiable as a recurring arrangement.
You become liable for the shortfall yourself, plus the standard late payment penalties — the withholding obligation sits with the Singapore payer, not the non-resident recipient.

No — IRAS looks at where management and control of the paying and receiving entities actually sit, not just which entity is named on the invoice.

Only non-resident directors. Singapore tax-resident directors are taxed under the normal personal income tax rules, not the Section 45 withholding regime.
It’s valid for the specific year it’s issued for — a new COR is needed every year treaty relief is claimed, it isn’t a one-time document.
Then the standard domestic withholding rate applies in full — DTA relief is only available where Singapore has an agreement with that specific country and the payee can provide a valid COR.