No. 11 of 2015 - EXEMPTION FROM WITHHOLDING TAX FOR QUALIFYING PAYMENTS MADE IN RESPECT OF QUALIFYING FINANCING ARRANGEMENTS OBTAINED FOR FINANCING SINGAPORE-FLAGGED SHIPS
MARITIME AND PORT AUTHORITY OF SINGAPORE
SHIPPING CIRCULAR
NO. 11 OF 2015
MPA Shipping Division
460 Alexandra Road
21st Storey PSA Building
Singapore 119963
Fax: 63756231
http://www.mpa.gov.sg
26 June 2015
Applicable to: This circular should be brought to the attention of all
Singapore-flagged ship owners that are assessed under Section 13A of the
Singapore Income Tax Act.
EXEMPTION FROM WITHHOLDING TAX FOR QUALIFYING PAYMENTS
MADE IN RESPECT OF QUALIFYING FINANCING ARRANGEMENTS
OBTAINED FOR FINANCING SINGAPORE-FLAGGED SHIPS
1 Automatic withholding tax (WHT) exemption is, subject to conditions,
granted on qualifying payments made on or after 1 June 2011 in respect of
qualifying loans entered into on or before 31 May 2016 to finance the
purchase or construction of Singapore-flagged ships1.
2 In his 2015 Budget Statement, the Deputy Prime Minister and Minister
for Finance announced that the automatic WHT exemption regime will be
extended to qualifying payments made on qualifying loans taken on or before
31 May 2021. In addition, the regime would be expanded to cover finance
leases treated as sale, hire purchase arrangements and loans used to finance
equity injection or intercompany loans to wholly-owned special purpose
vehicles for the purchase or construction of Singapore-flagged ships.
3 To enjoy the automatic WHT exemption, entities are required to submit
a self-declaration form (the “Form”) for each loan obtained to inform the
relevant authorities that the qualifying conditions have been met. The Form
has to be submitted to the MPA by the 15th of the month following the first
relevant payment due date to the non-resident. A copy of the Form (which
sets out the qualifying conditions for the automatic WHT exemption) is
attached as Annex A.
4 Should there be any changes to the representations/declarations made
in the Form, a new Form must be submitted immediately. Please submit the
duly completed and signed form, signed financing agreement as well as
documentary evidence (where required) to the Maritime and Port Authority of
Singapore, International Maritime Centre Division, 460 Alexandra Road, #19-
00 PSA Building, Singapore 119963. Please also email a soft copy of the
completed form to imc_mpa@mpa.gov.sg. To account for any non-disclosure
of material information, false or incorrect declarations made in the information
provided, the Government reserves the right to recover the taxes that should
have been withheld.
1 If an entity is unable to meet the qualifying conditions for the automatic WHT exemption, it may apply
to the Ministry of Finance for WHT exemption under Section 13(4) of the Singapore Income Tax Act.
5 Any queries relating to the filling up of the form and taxation matters
should be directed to the International Maritime Centre (IMC) Division’s
contact via email: imc_mpa@mpa.gov.sg or Tel: +65 6375 1927/1766.
Further matters relating to the registration of ships should be directed to Ms
Wan Fei Fei, Assistant Director (Registry), MPA, via Tel: (65) 6375 6228, Fax:
(65) 6375 6231, or to the Singapore Registry of Ships dedicated contact via
email: marine@mpa.gov.sg and Tel: (65) 6375 1932.
TAN SUAN JOW
DIRECTOR OF MARINE
MARITIME AND PORT AUTHORITY OF SINGAPORE
