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In brief

Budget 2023 focuses on building a more resilient and innovative Singapore. As the country emerges from the Covid-19 pandemic, the nation now contends with inflationary pressures in the midst of global uncertainty. Budget 2023 seeks to provide support to businesses and households to weather the challenges ahead while ensuring that Singapore continues to uphold fiscal prudence.

Importantly, the government has announced its intention to implement the OECD Pillar 2 measures from 2025 and confirmed that it will implement a domestic top-up tax which will top up multinational enterprise groups’ effective tax rate in Singapore to 15%. To remain competitive, Singapore will retain and extend its major tax incentives. Changes have also been made to buyer’s stamp duty rates, which are consistent with enhancing the fairness and resilience of Singapore’s tax system.

We highlight below the key tax developments from Budget 2023.


Key takeaways

  • Singapore plans to introduce the Global Anti-Base Erosion rules (i.e., Income Inclusion Rule and Undertaxed Profits Rule) and domestic top-up tax from in-scope businesses’ financial year starting on or after 1 January 2025. The domestic top-up tax will top up the multinational enterprise groups’ minimum effective tax rate in Singapore to 15%. 
  • There will be extensions and enhancements to various tax schemes, including the Pioneer Certificate Incentive, Development and Expansion Incentive, Investment Allowance scheme, Qualifying Debt Securities scheme and Financial Sector Incentive scheme.
  • A new Enterprise Innovation Scheme will be introduced to encourage businesses to engage in research and development, innovation and capability developments activities. Under this scheme, qualifying expenditure incurred on qualifying activities will be eligible for tax deductions or allowances of up to 400% but will generally be subject to a cap of $400,000. Businesses may also opt for a non-taxable cash payout of 20% on up to $100,000 of total qualifying expenditure across all qualifying activities per year of assessment, in lieu of tax deductions or allowances.
  • Higher marginal buyer’s stamp duty rates have been introduced for higher-value residential and non-residential properties. With effect from 15 February 2023, the buyer’s stamp duty rates are up to 6% for residential properties and 5% for non-residential properties.

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Author

Allen Tan is the head of the Tax, Trade and Wealth Management practice in Baker McKenzie Wong & Leow. He has extensive experience working on both international and local tax issues, with a special focus on the regional tax aspects of the transactions that he is involved in. Allen’s clients include Global Fortune 500 multinational corporations and major Singapore conglomerates. He is recognised as a leading lawyer for his tax controversy and corporate tax work in many leading legal and tax directories including International Tax Review, Chambers Asia Pacific and Legal 500 Asia Pacific. Allen was also named the Asia Tax Practice Leader of the Year 2018 by International Tax Review.

Author

Dawn Quek is a leading tax and private client lawyer in Singapore with many years of experience in corporate tax and international tax planning. She is the Head of the Wealth Management practice in Singapore and is the Asia Pacific representative on the Firm's Global Wealth Management Steering Committee. Dawn is consistently ranked as a leading tax and private client/wealth lawyer by various legal publications including Chambers High Net Worth (HNW) Guide, International Tax Review Women in Tax Leaders Guide and the Legal 500 Asia Pacific. She was named "Private Client Lawyer of the Year" at the 2018 Asia Legal Awards by The Asian Lawyer, and named "Women in Wealth Management" at the 2018 and 2020 WealthBriefingAsia Awards. Dawn is a key player in the local wealth management and financial services scene. She frequently participates in formal and informal consultations with government authorities on law reform on issues relating to the wealth management and financial services industry from a tax and legal perspective. She has also co-written articles on international tax planning issues in various tax and legal journals published by CCH and BNA. In addition, Dawn has been quoted extensively in publications such as the New York Times, the International Herald Tribune, Reuters, the Financial Times, the Straits Times, the Business Times and Asian Private Banker on issues and developments affecting the wealth management industry in Singapore.

Author

Shih Hui Lee has advised on both regional and Singapore tax issues, with focus on advising MNCs on international tax aspects of cross-border transactions. Her practice includes advising clients on tax issues arising from mergers and acquisitions, indirect taxes, transfer taxes, foreign direct investment and cross-border tax planning issues. Prior to joining Baker McKenzie, Shih Hui worked in one of the Big Four accounting firms in Singapore. She has experienced being an in-house regional tax advisor in one of the multinational cable and satellite television channel.

Author

Jaclyn has over 10 years of experience and specialises in solving the tax needs of multinational corporations and Singapore-headquartered companies across various industries globally and regionally.
She is adept at complex tax transformations to help clients unlock and maximise long term value, and achieve sustainable and tangible benefits, in tandem with business current and target operating models.
Jaclyn has extensive and deep experience in unlocking corporate synergies across the spectrum of tax-related services that Baker & McKenzie offers. Whether it is an international tax issue, restructuring strategies and implementation, intellectual property planning, M&A, or tax incentive negotiations with the relevant authorities, Jaclyn is a trusted advisor to her clients with her practical, sophisticated, innovative, and tailored solutions.
Jaclyn focuses on international taxation, cross-border taxation, group and business restructuring, transfer taxes and mergers and acquisitions.

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