Certificate of Residence (COR)

Purpose of the COR

The COR serves as formal proof to foreign tax authorities that the company or individual is a tax resident in Singapore. This allows the claimant to benefit from:

• Reduced withholding tax rates or total exemption on income like dividends, royalties, or interest received from foreign sources under DTAs.

• Prevention of double taxation on income earned internationally, improving tax efficiency and reducing overall tax liabilities.

• Enhancing credibility in cross-border trade and investment by establishing legitimate tax residency.

For example, a Singapore company receiving royalty income from Australia could submit a COR to the Australian tax authority to reduce withholding tax from 30% to 10% under the Singapore-Australia DTA.

Factors Considered by IRAS to Qualify for a COR

To issue a COR, IRAS assesses whether the company truly qualifies as a tax resident of Singapore based on the following factors:

1. Control and Management Exercised in Singapore

   • The company’s key strategic decisions (e.g., board resolutions, policy setting) must be made in Singapore.

   • Board meetings should be held in Singapore with key directors physically present.

2. Incorporation and Business Operations

   • The company must be incorporated in Singapore (generally).

   • It should have an actual office and business activities in Singapore, not just a nominal presence.

3. Key Personnel Presence

   • At least one director who holds an executive position (not a nominee director) must be based in Singapore.

   • Alternatively, having key management staff (e.g., CEO, CFO) physically present in Singapore.

4. For Foreign-Owned Investment Holding Companies

   • Usually ineligible unless able to demonstrate substantial economic activity and effective control in Singapore.

   • Must show business governance and decision-making occur here.

   • Evidence of related companies in Singapore or support services provided locally.

5. Valid Reasons for Setting up in Singapore

   • Demonstrable business rationale for operating in Singapore beyond just tax benefits.

6. Additional Requirement (Since 2025)

   • Companies must satisfy at least one of the conditions related to a director or key employee residing in Singapore or management by a related Singapore company.

How to Apply

COR applications must be submitted through the IRAS myTax Portal and can cover the current and up to 4 previous calendar years. The application involves submitting supporting documents including:

• Company financial statements

• Tax returns

• Evidence of board meetings and executive presence

IRAS typically processes applications within 7 working days.