Accounting Solutions Singapore Editorial Team · Last reviewed 24 October 2026
If your Singapore company is paid dividends, royalties, fees or interest from another country, that country may tax the payment before it reaches you. Singapore has tax treaties with many countries, and under them the rate can often be reduced or removed. To claim that, the foreign payer or tax authority usually wants proof that you are a Singapore tax resident. That proof is the Certificate of Residence, issued by IRAS.
At a glance
| Question | Short answer |
|---|---|
| What is it? | A letter from IRAS certifying that a company is a Singapore tax resident, used to claim benefits under a tax treaty (an Avoidance of Double Taxation Agreement, or DTA) |
| Who can apply? | A company that is a Singapore tax resident, meaning its business is controlled and managed in Singapore |
| Who generally can’t? | Nominee companies, foreign-owned investment holding companies with only passive or foreign income, and companies not incorporated in Singapore (including Singapore branches of foreign companies). IRAS makes exceptions in specific cases |
| Where? | myTax Portal, with Corppass |
| How long? | IRAS processes online applications within 7 working days |
| Which year? | A calendar year. You can apply for the current year, up to four earlier years, and one year in advance from October |
| When to apply? | Before you claim treaty benefits, or at the latest within 2 calendar years of the actual or expected date you receive the income |
What the COR does for you
Income a Singapore company earns from abroad may be taxed in that country. Under a treaty, a Singapore tax resident can often pay no tax, or a lower withholding rate, there. Non-residents get none of these benefits.
Example (illustration only). ABC Pte Ltd is a Singapore tax resident. It receives a royalty from a company in Australia, and Australia would withhold tax at 30%. If ABC gives the Australian tax authority its COR, the rate can fall to 10% under the Singapore-Australia treaty. On a S$100,000 royalty, that is S$10,000 withheld instead of S$30,000. The rates are those in IRAS’s own example. Check the current treaty rate for your income.
The COR does not lower your Singapore tax directly. If the treaty reduces the foreign tax rather than removing it, you may still pay tax in both countries. Singapore then lets you claim a credit for the foreign tax against the Singapore tax on the same income, known as foreign tax credit. Some treaties also add a condition, called a limitation of relief, that you must remit the income to Singapore.
What makes a company a Singapore tax resident
A company is resident in Singapore when its control and management is exercised in Singapore. IRAS defines that as making decisions on strategic matters such as the company’s policy and strategy. It is a question of fact, and the place of incorporation does not settle it.
Generally, a company is resident for a Year of Assessment if control and management was exercised in Singapore in the preceding calendar year. Residence can change from year to year.
IRAS looks at:
- whether board meetings are held in Singapore
- whether strategic decisions are made at those meetings
- whether the directors are based in or outside Singapore
- whether the local director makes strategic decisions
- whether key employees are based in Singapore
A board meeting held by video generally counts as making decisions in Singapore if at least 50% of the directors who can make strategic decisions are physically in Singapore, or the Chairman (if there is one) is physically in Singapore during the meeting.
IRAS issues a COR for a calendar year only if control and management is exercised in Singapore throughout that calendar year. Your financial year end makes no difference.
Who can apply
| Type of company | Position |
|---|---|
| Company controlled and managed in Singapore | Eligible |
| Nominee company | Not eligible. It is not the beneficial owner of the income |
| Foreign-owned investment holding company with only passive and/or foreign-sourced income | Generally not eligible, because it usually acts on its foreign shareholders’ instructions |
| Company not incorporated in Singapore, including a Singapore branch of a foreign company | Generally not eligible, as the foreign parent controls it |
| Variable capital company (VCC) | Eligible if tax resident. The VCC applies, not the sub-fund. The COR shows both |
A foreign-owned company is one where 50% or more of the shares are held by foreign companies or by individuals who are not Singapore citizens, applied at the ultimate holding company level.
IRAS may still issue a COR to a foreign-owned investment holding company if it shows that control and management is exercised in Singapore, with valid reasons for having an office here. To show a genuine commercial reason, it needs at least one of these:
- a director based in Singapore who holds an executive position and is not a nominee director
- a key employee (for example the CEO, CFO or COO) based in Singapore
- management by a related company based in Singapore
For a company not incorporated in Singapore, IRAS may issue one only in exceptional situations. The Singapore branch must be exercising full control and management, and the company must have valid reasons for not incorporating here.
Which year do you apply for?
The COR is for a calendar year. You can apply for the current calendar year and up to four earlier calendar years. From October you can also apply for one advance year. If the COR is granted for 2026, it means the company is a Singapore tax resident throughout 2026.
If you already hold an approved COR for the same country and calendar year, you don’t need to apply again. You can print or download it again from myTax Portal.
If a payment period or contract straddles two calendar years, apply for a COR for each year. IRAS gives this example: a service contract running from July 2020 to June 2021 needs a 2020 COR and a 2021 COR.
Example (illustration only). ABC Pte Ltd expects a service fee from an overseas customer in November 2026. In October it applies for a COR for calendar year 2026 and selects the customer’s country. Because it is already October, ABC can also apply for 2027 in advance if it expects more payments next year.
How to apply
- Set up Corppass access. A staff member or a third party such as a tax agent has to be authorised for “Corporate Tax (Filing and Applications)”. A Preparer can complete the application but can’t submit it. Only an Approver can approve and submit to IRAS. The Approver isn’t alerted when a Preparer submits, so tell them.
- Open the application in myTax Portal and choose the foreign country and the calendar year.
- Select the nature of income from IRAS’s list, which includes “Other Income”.
- Submit, then track. IRAS processes online applications within 7 working days.
- Download the COR from “View Notices/Letters – Corporate Tax” in myTax Portal. If your notice preference is email, you get an email within 1 to 3 working days saying it is ready and no paper copy is sent. If your preference is paper, the paper COR reaches your registered address within 4 working days.
Applying in writing
Only three cases apply in writing, through myTax Mail:
- a sole proprietorship owned by the company
- a partnership in which the company is a partner
- a company not incorporated in Singapore
The letter should give the name and UEN, the reason for the COR, the calendar year, the foreign jurisdiction, the nature and amount of income, the name of the foreign payer, the date of remittance, and a confirmation that control and management of the business is or will be in Singapore for the whole calendar year. IRAS processes written applications within 14 working days of receiving complete information, longer for complex cases.
If you don’t need treaty benefits
If you only want a letter confirming that the company is a Singapore tax resident, and are not claiming treaty benefits, IRAS has a separate Application for Letter of Residence.
When the foreign authority wants its own form
Some countries ask for a tax reclaim form, with or in place of a COR. IRAS may need to certify it.
- Post the original signed form (not a photocopy) to the Inland Revenue Authority of Singapore.
- IRAS cannot certify incomplete forms: ones not signed by authorised persons, with missing information, or back-dated or post-dated. The form should carry the current date.
- IRAS processes it within 1 month of receiving a complete, signed form, and in most cases within 2 weeks. The certified form and a cover letter are mailed to your registered address. A copy of the cover letter appears in myTax Portal.
- There is no charge.
- Indonesia: DGT Form 1 and DGT Form 2 do not need IRAS’s certification. Send the COR with the completed form. The forms are valid for the calendar year on the COR.
Copies of the COR
- Printing another copy from myTax Portal is free, and you don’t need to reapply.
- IRAS digitally signs the COR, and treaty partners generally accept it without a stamped or certified copy. IRAS does not accept requests for wet-ink stamping or true-copy certification.
- In the rare case a foreign tax authority insists on it, you can email IRAS with proof of that requirement. IRAS then processes the request at a fee, with a document search fee of S$20 per certified copy and S$3 for each page. The certified COR should reach your registered address within 10 working days of your reply after payment.
- A hardcopy duplicate by post is available at a fee. IRAS’s page does not state the amount.
Where mistakes happen
- Control and management isn’t actually in Singapore. If the board meets and decides overseas, you may not qualify.
- Wrong year. The COR is for a calendar year. A contract that straddles two years needs two CORs.
- Wrong country or income type selected. Check it matches what the foreign payer expects.
- Waiting until the foreign payer asks. Apply before you claim, and no later than 2 calendar years from when the income is received or expected. You can apply in advance from October.
- Nobody has Approver access. Applications stall when only a Preparer has been set up.
Foreign income and Singapore tax
Foreign income is generally taxable in Singapore when it is remitted to and received here. If it arises from a trade or business carried on in Singapore, it is taxable when it accrues, whether or not it is received here.
Singapore tax resident companies get three reliefs on foreign income: treaty benefits, tax exemption on specified foreign-sourced income, and foreign tax credit. The exemption covers foreign-sourced dividends, foreign branch profits and foreign-sourced service income remitted to Singapore. All three conditions must be met:
- the income was taxed in the country it came from
- that country’s highest corporate tax rate is at least 15% when the income is received in Singapore
- the Comptroller of Income Tax is satisfied that the exemption benefits the company
Expenses on that income are deducted against it, and not against other taxable income. You claim the exemption in your Corporate Income Tax return (Form C), or in the tax computation if you file Form C-S or C-S (Lite), and keep the supporting documents for at least 5 years from the relevant Year of Assessment.
If you are the one paying overseas
A COR is for companies that receive foreign income. If your Singapore company pays a non-resident, different rules apply. You may need to withhold tax and file the withholding tax form (S45, also called IR37). If the overseas payee is claiming treaty relief, you still file even when no tax is withheld. See our page on withholding tax.
Questions we get asked
Does the COR lower my tax in Singapore? Not by itself. It supports a claim for treaty benefits in the other country, such as a lower withholding rate there. Foreign tax credit and the foreign-sourced income exemption are separate reliefs in Singapore.
How much does it cost? IRAS’s application page lists no fee for the COR. It charges for hardcopy duplicates and certified copies, as above.
How long is a COR valid? It is for a specific calendar year. For example, a COR for 2021 means the company was a Singapore tax resident for 2021. IRAS’s page gives no separate validity period.
Does a Singapore holding company qualify? If it is a Singapore tax resident and not a nominee company, it can apply. A foreign-owned investment holding company with only passive or foreign income is generally treated as non-resident unless it meets the conditions above. IRAS looks at where control and management really sit.
Is a Singapore branch of a foreign company eligible? Generally not. IRAS may make an exception if the branch exercises full control and management and has valid reasons for not incorporating here.
Can a tax agent apply for me? Yes, if authorised in Corppass. An Approver must submit.
Can I apply for the COR after the income is paid? Yes, within 2 calendar years from the actual or expected date of receipt, and up to four earlier calendar years on myTax Portal.
Get help with your Certificate of Residence
Tell us the country, the type of income and when payment is due. We’ll tell you whether you can apply, for which year, and what’s needed. Get help with your Certificate of Residence. Related: corporate tax.
Sources
- IRAS, Tax residency of a company / Certificate of Residence
- IRAS, Applying for a Certificate of Residence / tax reclaim form
- IRAS, Companies receiving foreign income
- IRAS, FAQs: Apply for a Certificate of Residence (updated 15 December 2021)
This page is general information as at the date above, not legal, regulatory or professional advice. Rules change, so please take advice on your own circumstances before acting.