GST Zero Rating on Supply of Services

It is important to note that, unlike the export of goods, not all services supplied outside of Singapore can be zero-rated. This is because Singapore’s GST Act states that zero rating can only apply to services that fall within the description of international services under Section 21(3).  What this means is that even if your supply of services is performed completely outside Singapore, it may not be zero-rated if it does not fall within the list of services described in Section 21(3).


For example, your company was engaged by a local Singaporean company to perform consultancy services outside of Singapore. To most people, this supply should be zero-rated because it was performed overseas as Singapore’s GST only applies to goods and services supplied in Singapore. You are wrong if you think this should be the case. This is because consultancy services do not fall within the description of international services that qualify for zero-rating, as provided for under Section 21(3).


So it is of utmost importance to actually make sure that you should only zero rate your supply of services if it falls within the description of international services under Section 21(3).


To compound the difficulty further, depending on the nature of the services provided, you are also required to determine the belonging status of your customer – whether your customer is a local person or an overseas person, for a zero rating to apply. Your customer can also be either an individual or a business.


The test to determine the belonging status of an individual and a business is different. For an individual, the usual place of residence test is used to determine whether your customer belongs to a country outside Singapore for a zero rating to apply. Whereas a business, it must not have a business establishment or some fixed establishment in Singapore for it to be treated as belonging outside Singapore.


Therefore it is essential to bear in mind that not all services provided to overseas customers can be zero-rated.


Consult a GST expert to know more about this.

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ACRA Cancels Registration of Filing Agent and Qualified Individual for AML/CFT Breaches

The Accounting and Corporate Regulatory Authority (ACRA) had cancelled the registrations of filing agent (RFA) and qualified individual (RQI) on 18 January 2024. The registrations were cancelled in view of breaches of anti-money laundering and countering the financing of terrorism (AML/CFT) controls under the ACRA (Filing Agents and Qualified Individuals) Regulations 2015 (the “ACRA Regulations”).

Some of the basic AMT/CFT controls that a RFA and RQI are required to exercise are as follows:

(a) perform additional customer due diligence measures when a customer is not physically present during onboarding;

(b) inquiring if there exists any beneficial owner in relation to some of its customers; and

(c) perform risk assessments i

RQIs and RFAs provide corporate secretarial services for business entities, such as helping customers to incorporate companies, file annual returns and fulfil other filing requirements under the Companies Act 1967 or other Acts under ACRA’s purview. RQIs and RFAs are required to perform customer due diligence measures in accordance with the ACRA Regulations, and conduct their business in such a manner as to guard against the facilitation of money laundering and the financing of terrorism. RQIs and RFAs must also satisfy statutory requirements such as being fit and proper persons, to be registered or continue to be registered.

RQIs and RFAs who breach their statutory obligations may be subject to enforcement actions, such as financial penalties of up to $10,000 or $25,000 per breach respectively or have their registrations with ACRA suspended or cancelled.

Therefore, RQIs and RFAs play an important role in helping to detect and combat illicit activities.

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