Together, a better future

Transcription

1 Budget 2018 News Alert Together, a better future At a glance Overcoming near-term challenges Fostering pervasive innovation Building deep capabilities Encouraging a spirit of giving Enhancing progressivity, fairness and resilience of our tax system Other changes The Minister for Finance, Mr. Heng Swee Keat, delivered the Singapore Budget for financial year 1 April 2018 to 31 March 2019 in Parliament on 19 February Singapore s economy grew by 3.6% in 2017, up from 2.4% in The Ministry of Trade and Industry expects the Singapore economy to grow between 1.5% and 3.5% for the year Budget 2018 focuses on laying down a strategic and integrated plan to position Singapore for the future and prepare the nation to take on three major shifts in the coming decade the shift in global economic weight towards Asia, emergence of new technologies and aging population of Singapore. Specifically, the Budget seeks to prepare Singapore to guard against the challenges and capture opportunities through developing the nation into a more vibrant and innovative economy, building a smart, green and liveable city, fostering a caring and cohesive society and planning ahead for a fiscally sustainable and secure future. A number of tax changes were announced to provide near-term support to businesses, foster pervasive innovation, encouraging capabilities building and forging of partnerships, all with the aim of building a better future together for Singapore. 1 l Budget 2018 News Alert

2 Overcoming near-term challenges 1. Enhancing and extending the corporate income tax (CIT) rebate: For the year of assessment (YA) 2018, the CIT rebate will be increased from 20% of tax payable to 40% of tax payable and the cap will be raised from S$10,000 to S$15,000. Further, the CIT rebate will be extended for another year to YA 2019 with a reduced rate of 20% of tax payable, capped at S$10,000. Fostering pervasive innovation 2. Enhancing the tax deduction for qualifying expenditure on qualifying R&D projects performed in Singapore: To support businesses in building their own innovations, the tax deduction for staff costs and consumables incurred on qualifying R&D projects performed in Singapore will be increased from 150% to 250%. All other conditions of the scheme remain unchanged. This change will take effect from YA 2019 to YA Enhancing the tax deduction for costs on protecting intellectual property (IP): To encourage businesses to register and protect their IPs, the existing 100% tax deduction on qualifying IP registration costs, which is scheduled to lapse after YA 2020, will be extended to YA Further, the tax deduction will be increased to 200% for the first S$100,000 of qualifying IP registration costs incurred for each YA. This change will take effect from YA 2019 to YA Enhancing the tax deduction for costs on IP in-licensing: To support businesses in buying and using new solutions, the existing 100% tax deduction for qualifying IP in-licensing costs will be increased to 200% for the first S$100,000 of qualifying IP in-licensing costs incurred for each YA. Qualifying IP in-licensing costs include payments made by a qualifying person to publicly funded research performers or other businesses, but exclude related party licensing payments, or payments for IP where any allowance was previously made to that person. This change will take effect from YA 2019 to YA Building deep capabilities 5. Enhancing the double tax deduction for internationalisation (DTDi) scheme: To further encourage internationalisation, the expenses cap for the existing automatic double tax deduction will be increased from S$100,000 to S$150,000 per YA for qualifying expenses incurred on or after YA All other conditions of the scheme remain unchanged. IE Singapore (IES) and Singapore Tourism Board will release further details by April Adjustment to the Start-Up Tax Exemption (SUTE) scheme: The SUTE scheme will be adjusted to provide for 75% exemption on the first S$100,000 of normal chargeable income (NCI) and 50% exemption on the next S$100,000 of NCI. All other conditions of the scheme remain unchanged. This change will take effect on or after YA 2020 for all qualifying companies. 2 l Budget 2018 News Alert

3 7. Adjustment to the Partial Tax Exemption (PTE) scheme: The PTE scheme will be adjusted to provide for 75% exemption on the first S$10,000 of NCI and 50% exemption on the next S$190,000 of NCI. All other conditions of the scheme remain unchanged. This change will take effect on or after YA 2020 for all companies (except those that qualify for the SUTE scheme) and bodies of persons. Encouraging a spirit of giving 8. Extending the 250% tax deduction for qualifying donations: The existing 250% tax deduction for qualifying donations made between 1 January 2016 and 31 December 2018 will be extended for donations made on or before 31 December All other conditions of the scheme remain unchanged. 9. Extending the Business and IPC Partnership (BIPS) scheme: To continue to support employee volunteerism through businesses, the qualifying period for the existing BIPS scheme, scheduled to lapse after 31 December 2018, will be extended to 31 December Enhancing progressivity, fairness and resilience of our tax system 10. Introducing goods and services tax (GST) on imported services: To ensure a fair and resilient tax system in a digital economy, GST will be introduced on imported services on or after 1 January B2B imported services will be taxed via a reverse charge mechanism. Only businesses that make exempt supplies or do not make any taxable supplies need to apply reverse charge. The taxation of B2C imported services will take effect through an Overseas Vendor Registration mode, which requires overseas suppliers and electronic marketplace operators that make significant supplies of digital services to local consumers to register with the Inland Revenue Authority of Singapore (IRAS) for GST. The IRAS will release further details by end February Increasing the GST rate: To support the expected increase in healthcare, security and other social spending, the GST rate will be raised from 7% to 9% some time in the period between 2021 and The exact timing will depend on the state of the economy, how much the expenditures grow, and how buoyant the existing taxes are. Other changes 12. Introducing a tax framework for Singapore Variable Capital Companies (S-VACCs): A tax framework for S-VACC (a new structure designed for collective investment schemes) will be introduced to complement the S-VACC regulatory framework where: a) An S-VACC will be treated as a company and a single entity for tax purposes b) Tax exemption under sections 13R and 13X of the Income Tax Act (ITA) will be extended to S-VACCs c) 10% concessionary tax rate under the Financial Sector Incentive Fund Management scheme will be extended to approved fund managers managing an incentivised S-VACC 3 l Budget 2018 News Alert

4 d) The existing GST remission for funds will be extended to incentivised S-VACCs The conditions under the existing schemes in (b), (c) and (d) remain unchanged. The changes will take effect on or after the effective date of the S-VACC regulatory framework. 13. Enhancing the Enhanced-Tier Fund scheme under section 13X of the ITA: To cater for more diverse fund structures, the tax exemption under this scheme, which is originally available only for companies, trusts and limited partnerships, will be extended to all fund vehicles constituted in all forms provided that they meet all qualifying conditions. All other conditions of the scheme remain unchanged. The change will take effect for new awards approved on or after 20 February The Monetary Authority of Singapore (MAS) will release further details by May Extending the tax transparency treatment for Singapore-listed Real Estate Investment Trusts (S-REIT) to Singapore-listed Real Estate Investment Trusts Exchange-Traded Funds (REIT ETF): To provide for parity in tax treatments between investing in S-REITs and REITs ETFs that invest in S-REITs, the following tax treatment will be accorded to REITs ETFs: a) Tax transparency treatment on the distributions received by REITs ETFs from S-REITs, which are made out of the latter s specified income b) Tax exemption on such REITs ETFs distributions received by individuals, excluding individuals who derive any distribution: i) Through a partnership in Singapore; or ii) From the carrying on of a trade, business or profession; and c) Ten percent concessionary tax rate on such REITs ETFs distributions received by qualifying non-resident non-individuals Subject to conditions, the tax concessions for REITs ETFs will take effect on or after 1 July 2018, with a review date of 31 March 2020, which is the same date as that for other tax concessions for S-REITs. The application for the tax transparency treatment can be submitted to the IRAS on or after 1 April The MAS and IRAS will release further details by March Extending and enhancing the Financial Sector Incentive (FSI) scheme: The FSI scheme, which accords concessionary tax rates of 5% to 13.5% on income from qualifying activities, scheduled to lapse after 31 December 2018, will be extended to 31 December The scope of trading in loans and their related collaterals will be expanded to include collaterals that are prescribed infrastructure assets or projects. This change will apply to income derived on or after 1 January 2019 in respect of new and renewal awards approved on or after 1 June All other conditions of the scheme remain unchanged. The MAS will release further details by May l Budget 2018 News Alert

5 16. Extending the Insurance Business Development Insurance Broking Business (IBD IBB) scheme and allowing the Insurance Business Development Specialised Insurance Broking Business (IBD SIBB) scheme to lapse: The IBD IBB scheme, which grants approved insurance and reinsurance brokers a concessionary tax rate of 10% on commission and fee income derived from insurance broking and advisory services, scheduled to lapse after 31 March 2018, will be extended to 31 December All conditions of the IBD-IBB scheme remain unchanged. The IBD-SIBB scheme, which grants insurance and reinsurance brokers a concessionary tax rate of 5% on commission and fee income from specialty insurance broking activities, will be allowed to lapse after 31 March With the lapse of the IBD-SIBB scheme, specialty insurance broking and advisory services will be incentivised under the IBD-IBB scheme at a concessionary tax rate of 10%. The MAS will release further details by May Extending the tax deduction for banks (including merchant banks) and qualifying finance companies for impairment and loss allowances made in respect of non-credit-impaired financial instruments: Section 14I of the ITA (which allows tax deduction for impairment losses on non-credit-impaired loans and debt securities made under Financial Reporting Standard 109, and any additional loss allowances as required under MAS Notices 612, 811 and 1005), scheduled to lapse after YA 2019 (for banks and qualifying finance companies with December financial year-end (FYE)) or YA 2020 (for banks and qualifying finance companies with non- December FYE), will be extended until YA 2024 (for banks and qualifying finance companies with December FYE) or YA 2025 (for banks and qualifying finance companies with non-december FYE). All other conditions of the scheme remain unchanged. The MAS will release further details by May Rationalising the withholding tax (WHT) exemptions for the financial sector: As part of the government s process to continually review tax concessions to ensure relevance and usefulness, the following changes will be made: a) A review date of 31 December 2022 will be introduced for the WHT exemptions for the following payments: i) Payments made under cross currency swap transactions made by Singapore swap counterparties to issuers of Singapore dollar debt securities ii) Payments made under interest rate or currency swap transactions by financial institutions iii) Payments made under interest rate or currency swap transactions by the MAS iv) Specified payments made under securities lending or repurchase agreements by specified institutions; and b) The following WHT exemptions will be legislated, along with a review date of 31 December 2022: i) Interest on margin deposits paid by members of approved exchanges for transactions in futures ii) Interest on margin deposits paid by members of approved exchanges for spot foreign exchange transactions (other than those involving Singapore dollar) 5 l Budget 2018 News Alert

6 The change in (b) will take effect for payments under agreements entered into on or after 20 February c) The WHT exemptions for the following payments will be withdrawn: i) Interest from approved Asian Dollar Bonds ii) Payments made under over-the counter financial derivative transactions by companies with FSI Derivatives Market awards that were approved on or before 19 May 2007 The change in (c) will take effect for payments under agreements entered into on or after 1 January All other conditions of the schemes remain unchanged. The MAS will release further details by May Extending the tax incentive scheme for Approved Special Purpose Vehicle (ASPV) engaged in asset securitisation transactions (ASPV scheme): The ASPV scheme which is scheduled to lapse after 31 December 2018, grants the following tax concessions to an ASPV engaged in asset securitisation transactions: a) Tax exemption on income derived by an ASPV from approved asset securitisation transactions b) GST recovery on its qualifying business expenses at a fixed rate of 76% c) WHT exemption on payments to qualifying non-residents on over-the counter financial derivatives in connection with an asset securitisation transaction d) Remission of stamp duties on the instrument relating to transfer of assets to the ASPV for approved asset securitisation transactions To continue to develop the structured debt market, the ASPV scheme will be extended to 31 December 2023, with the exception of stamp duty remission in (d), which will be allowed to lapse after 31 December All other conditions of the scheme remain unchanged. The MAS will release further details by May Extending the Qualifying Debt Securities (QDS) incentive scheme and allowing the Qualifying Debt Securities Plus (QDS+) incentive scheme to lapse: To continue to support the development of Singapore s debt market, the QDS scheme, which is scheduled to lapse after 31 December 2018, will be extended to 31 December The QDS+ scheme will be allowed to lapse after 31 December The MAS will release further details by May l Budget 2018 News Alert

7 21. Extending the tax exemption on income derived by primary dealers from trading in Singapore Government Securities (SGS): The tax exemption on income derived by primary dealers from trading in SGS, scheduled to lapse after 31 December 2018, will be extended to 31 December The MAS will release further details by May Extending the Investment Allowance (IA) scheme to include qualifying investment in submarine cable systems landing in Singapore: IA, in respect of productive equipment, will be extended to capital expenditure incurred on newly constructed strategic submarine cable systems landing in Singapore, subject to qualifying conditions. All other conditions of the IA scheme apply, except for the following which will be permitted: a) The submarine cable systems can be used outside Singapore b) The submarine cable systems, on which IA has been granted, can be leased out under the indefeasible rights of use arrangements The change will take effect for capital expenditure incurred between 20 February 2018 and 31 December 2023, inclusive of both dates. 23. Introducing a review date for the WHT exemption on container lease payments made to non-resident lessors: WHT exemption is allowed on lease payments made to non-resident lessors (excluding permanent establishment in Singapore) for the use of qualifying containers for the carriage of goods by sea. A review date of 31 December 2022 will be introduced to ensure that the relevance of the scheme is periodically reviewed. 24. Raising Buyer s Stamp Duty (BSD) on the value of residential property in excess of S$1m: The top marginal BSD rate will be raised from 3% to 4%, and applied on the value of residential property in excess of S$1m as follows: a) On the first S$180,000, BSD rate of 1% b) On the next S$180,000, BSD rate of 2% c) On the next S$640,000, BSD rate of 3% d) On the amount exceeding S$1m, BSD of 4% The revised rates will apply to all residential properties acquired on or after 20 February There will be a transitional provision for cases where an Option to Purchase (OTP) has been granted by sellers to potential buyers on or before 19 February For such cases, the current BSD rates, instead of the revised BSD rates, will apply if the OTP is exercised on or before 12 March 2018 or the OTP validity period, whichever is earlier. The BSD rates for non-residential properties remain unchanged. 7 l Budget 2018 News Alert

8 25. Implementing carbon tax on greenhouse gas emissions: To encourage companies to reduce greenhouse gas emissions, a carbon tax of S$5 per tonne of greenhouse gas emissions will be imposed from 2019 to 2023 on all facilities that produce 25,000 tonnes or more of greenhouse gas emissions in a year. The carbon tax will apply uniformly across all sectors without exemption. The carbon tax rate will be reviewed by 2023 and is intended to increase to a rate of between S$10 and S$15 per tonne of emissions by More grants and support will be provided to companies and households to help them enhance energy efficiency. 26. Extending the Wage Credit Scheme (WCS): The WCS, which co-funds wage increases for Singaporean employees up to a gross monthly wage of S$4,000 will be extended for three years up to The WCS will co-fund 20% of qualifying wage increases in 2018, 15% of qualifying wage increases in 2019 and 10% of qualifying wage increases in All other conditions remain unchanged. 27. Productivity Solutions Grant (PSG): To make it easier for businesses to access support to adopt technologies and productivity solutions, the existing grant schemes that support pre-scoped, off-the-shelf productivity solutions will be streamlined into one PSG. The PSG will provide funding support of up to 70% of qualifying costs. Businesses can apply for the PSG through the Business Grants Portal (BGP) with effect from 1 April Enterprise Development Grant (EDG): To provide more holistic and customised support to local enterprises seeking to build deep capabilities, scale up, and internationalise, SPRING Singapore s Capability Development Grant and IES Global Company Partnership grant will be combined into the EDG. The EDG will provide funding support of up to 70% of qualifying costs from financial year (FY) 2018 to FY Businesses can apply for the EDG through the BGP with effect from the fourth quarter of Combining the existing grant schemes into the Partnership for Capability Transformation scheme (PACT scheme): To provide more holistic support to encourage collaboration between enterprises of all sizes, the existing grant schemes that support various forms of partnerships between companies will be combined into the PACT scheme. PACT will provide funding support of up to 70% of qualifying costs, for collaborations between companies in areas including capability upgrading, business development, and internationalisation. 30. Setting up of Infrastructure Office (IO): An IO will be set up to bring together local and international partners across the value chain, including infrastructure developers, institutional investors, multilaterals, and legal, accounting, and financial services providers. This will provide a platform for information exchange on infrastructure opportunities in Asia, facilitate infrastructure investments and financing, and enable infrastructure players in the region to tap on these opportunities. The IO will be set up by Enterprise Singapore and the MAS later this year. Prepared by: Tan Ching Khee, Partner and Toh Ai Tee, Director, Tax Services, Singapore, Ernst & Young Solutions LLP 8 l Budget 2018 News Alert

9 EY Tax leadership If you would like to know more about our services or the issues discussed, please contact: Chung-Sim Siew Moon Partner and Head of Tax Singapore Tax Partners, Executive Directors and Directors Business Tax Services Angela Tan Lim Gek Khim Russell Aubrey Helen Bok Choo Eng Chuan Goh Siow Hui Lim Joo Hiang Ang Sau Tze Toh Ai Tee Toh Shuhui Tax Policy and Controversy Chung-Sim Siew Moon Business Incentives Advisory Tan Bin Eng Private Client Services Koh Chin Chin Global Compliance and Reporting Soh Pui Ming Chai Wai Fook Chia Seng Chye Ivy Ng Tan Ching Khee Teh Swee Thiam Nadin Soh Chionh Huay Kheng Grace Ng Corporate Services David Ong Financial Services Organisation Amy Ang Stephen Bruce Desmond Teo Louisa Yeo Mriganko Mukherjee Moong Jee See Helen Tindle Michele Chen Rajesh Bheemanee Indirect Tax Global Trade Adrian Ball GST Services Yeo Kai Eng Chew Boon Choo International Tax Services International Tax Chester Wee Wong Hsin Yee Aw Hwee Leng Transfer Pricing Luis Coronado Stephen Lam Jonathan Bélec Sharon Tan Singapore Budget 2018 Synopsis

10 Asia-Pacific Tax Centre India Tax Desk Gagan Malik UK Tax Desk Billy Thorne Korea Tax Desk Chung Hoon Seok Japan Tax Desk Hiroki Shinozaki US Tax Desk Garrett Davidson Indirect Tax Global Trade Donald Thomson Indirect Tax GST Tracey Kuuskoski Life Sciences Richard Fonte Operating Model Effectiveness Edvard Rinck Nick Muhlemann Paul Griffiths Braedon Clark People Advisory Services Mobility Grahame Wright Kerrie Chang Panneer Selvam Sarah Lane Wu Soo Mee Tina Chua Grenda Pua Pang Ai Lin Talent and Reward Samir Bedi Transaction Tax Darryl Kinneally Sandie Wun Industry sectors Real Estate Lim Gek Khim Ivy Ng Technology, Media and Telecommunications Chia Seng Chye Resources Angela Tan Consumer Products & Retail Soh Pui Ming Life Sciences Tan Ching Khee Diversified Industrial Products Russell Aubrey Government & Public Sector Tan Bin Eng Hospitality Helen Bok Shipping Goh Siow Hui Emerging & Private Enterprise Chai Wai Fook China Overseas Investment Network Tan Ching Khee Insurance Amy Ang Wealth & Asset Management Desmond Teo Banking & Capital Markets Stephen Bruce Singapore Budget 2018 Synopsis 2

11 EY Assurance Tax Transactions Advisory About EY EY is a global leader in assurance, tax, transaction and advisory services. The insights and quality services we deliver help build trust and confidence in the capital markets and in economies the world over. We develop outstanding leaders who team to deliver on our promises to all of our stakeholders. In so doing, we play a critical role in building a better working world for our people, for our clients and for our communities. EY refers to the global organisation, and may refer to one or more, of the member firms of Ernst & Young Global Limited, each of which is a separate legal entity. Ernst & Young Global Limited, a UK company limited by guarantee, does not provide services to clients. For more information about our organisation, please visit ey.com Ernst & Young Solutions LLP. All Rights Reserved. APAC No ED None Ernst & Young Solutions LLP (UEN T08LL0784H) is a limited liability partnership registered in Singapore under the Limited Liability Partnerships Act (Chapter 163A). This document contains general information and should not be construed as legal, tax, accounting or any other professional advice or service. You should consult with a professional advisor familiar with your particular factual situation for advice concerning specific tax or other matters before making any decision. Ernst & Young Solutions LLP disclaims all liability and responsibility to you in respect of the content in this document l Budget 2018 News Alert