新加坡海外收入汇回:2026年公司与个人的纳税规则与免税条件
海外收入汇回新加坡何时需纳税?本文解析第10(25)条“汇入”定义、第13(8)条三项免税条件、外国税收抵免、第10L条及文件留存要求。
Published: 8 October 2026 · Last reviewed: 14 October 2026 · Reviewed by Ray Tay, Co-Founder & Managing Director, VIVOS PTE. LTD. (ACRA Filing Agent FA20240323 · MOM EA Licence 24S2425)
A Singapore company running a team through a Malaysian subsidiary must get three things right: how it receives Malaysian dividends, how it invoices the subsidiary, and who holds which work pass.
This is the Singapore-side companion to our Episode 2 guide, Singapore HQ, Malaysia Team: How the Structure Works (2026), in VIVOS Group’s Two Jurisdictions, One Team series. Watch the explainer on YouTube.
Usually not. Section 13(8) of the Income Tax Act exempts foreign-sourced dividends received by a Singapore resident company if the income was subject to tax in the source country, that country’s headline corporate rate is at least 15%, and IRAS is satisfied the exemption is beneficial. Malaysia does not withhold tax on dividends, but the subsidiary’s own corporate tax counts as underlying tax, and Malaysia’s headline rate is 24%. There is no minimum shareholding. Declare the exemption in the tax return and keep dividend vouchers and Malaysian notices of assessment in case IRAS asks (IRAS e-Tax Guide, Tax Exemption for Foreign-Sourced Income). More in our guide to foreign-sourced income in Singapore.
Under a written intercompany agreement, at an arm’s-length price. On management or technical fees, the subsidiary withholds 5% under the treaty (10% without it) on the part performed in Malaysia and pays LHDN within one month. Give the subsidiary your IRAS certificate of residence so the treaty rate applies. Singapore relieves double taxation on treaty-country income through a foreign tax credit, subject to conditions (PwC Worldwide Tax Summaries, Singapore).
IRAS requires transfer pricing documentation where gross revenue exceeds S$10 million, or where it was required the previous year. From YA 2026, related-party service transactions up to S$2 million per category (S$1 million before) are exempt, as are routine support services charged at cost plus 5% (IRAS Transfer Pricing Guidelines, 7th edition, 14 June 2024). Malaysia applies its own rules under section 140A, so both companies should tell the same pricing story.
Each pass follows the local employer, so decide where each person works. A Singapore Employment Pass needs at least S$5,600 a month (more for older candidates), rising to S$6,000 for new applications from 1 January 2027 and renewals expiring from 1 January 2028, plus the COMPASS points test (MOM). A Malaysian Employment Pass needs a contract with the Malaysian company and a basic salary of at least RM5,000 a month (RM20,000 for Category I); salary paid outside Malaysia does not count. See our video on the 2027 EP change.
Commuting, mostly. LTA targets passenger service at the end of 2026 on the 4 km link from Woodlands North to Bukit Chagar in Johor Bahru: about five minutes, with immigration cleared once at departure (LTA factsheet, 11 January 2024). Treat the date as a target; tax and work-pass rules do not change with the train.
Usually not. They can be exempt under section 13(8) because the profits were taxed in Malaysia and Malaysia’s 24% headline rate is above 15%.
Only if its gross revenue exceeds S$10 million (or documentation was required the year before), and not for service transactions within the S$2 million per category exemption from YA 2026.
S$6,000 a month for new applications in most sectors (S$6,600 in financial services), with higher amounts for older candidates.
LTA’s target is the end of 2026. Check LTA for the confirmed date.
Related: Malaysia-side checklist · two-jurisdiction structures hub. Book a free consultation at vivos.com.sg/contact-us or WhatsApp +65 8827 7870.
Facts checked 5 October 2026; reviewed by Ray Tay, VIVOS. General information, not tax advice. VIVOS PTE. LTD. · UEN 202416468C · ACRA Registered Filing Agent FA20240323 · MOM EA Licence 24S2425 · 14B Stanley Street, Singapore 068733.
海外收入汇回新加坡何时需纳税?本文解析第10(25)条“汇入”定义、第13(8)条三项免税条件、外国税收抵免、第10L条及文件留存要求。
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