2024 02 20 – SINGAPORE: TAX MEASURES IN BUDGET 2024 INCLUDE PILLAR TWO GLOBAL MINIMUM TAX RULES

Executive Summary:

The 2024 Singapore Budget introduces additional sector-specific tax measures to stimulate growth and innovation in key industries. New concessionary tax rates (CTR) are being introduced for industries such as aircraft leasing, finance, and intellectual property. For example, the Aircraft Leasing Scheme will now offer a 10% CTR, while the Development and Expansion Incentive and Global Trader Programme will have a 15% CTR. These tax rates are designed to support businesses in these sectors, although companies must meet specific economic commitments, such as headcount and spending, to qualify.

While these new CTRs provide tax relief, there is concern that the difference between the new rates and the existing corporate tax rate of 17% may reduce their attractiveness. The economic commitments required to qualify for these incentives could be less favorable compared to previous years. Additionally, the Budget introduces a new tax framework for selected Maritime Section Incentive (MSI) sub-schemes, where qualifying income will now be taxed based on net tonnage starting from YA 2024. These changes reflect the government’s focus on maintaining Singapore’s competitiveness in global industries while encouraging growth and innovation.

The 2024 Singapore Budget includes proposals to implement the Pillar Two global minimum tax rules, effective for financial years beginning 1 January 2025.

Other proposed tax measures in the 2024 Budget include:

  • Introduction of an additional concessionary tax rate tier for various incentives
  • Extension of the fund tax incentive scheme, along with withholding tax exemptions and GST exemptions for qualifying funds, until 31 December 2029
  • Introduction of a Refundable Investment Credit (RIC) scheme to attract substantial, high-value economic activities
  • Implementation of an alternative tax basis for selected maritime sector incentive sub-schemes
  • A 50% corporate income tax rebate, capped at S$40,000, along with a minimum cash payout of S$2,000