One of the most common questions among new business owners in Singapore is:
Can a non-GST registered company charge GST to its clients?
The general answer is no.
A business that is not registered for Goods and Services Tax (GST) generally cannot charge or collect Singapore GST from its customers.
Only businesses that are GST-registered are authorised to charge and collect GST on their taxable supplies from the effective date of their GST registration.
This distinction is extremely important.
A business cannot simply decide to add 9% GST to its invoices because its suppliers are charging it GST, because it expects to become GST-registered soon, or because its customers are GST-registered.
If your company is not GST-registered, you should generally invoice customers without adding a separate Singapore GST charge.
There are narrow exceptions for particular statutory situations, but these are not the ordinary sale of goods or services by a non-GST-registered company.
This article explains how the rules work, what happens if a non-GST-registered company wrongly charges GST, how GST should be treated in the company’s accounting records and when a business should consider registering for GST.
What Is GST in Singapore?
Goods and Services Tax is a broad-based consumption tax imposed on the import of goods and most supplies of goods and services in Singapore.
The prevailing Singapore GST rate is 9%.
GST-registered businesses generally collect GST from customers on their standard-rated supplies and account for the output tax to the Inland Revenue Authority of Singapore (IRAS).
At the same time, GST-registered businesses may generally claim qualifying GST incurred on business purchases as input tax, subject to the applicable rules and conditions.
For example, assume a GST-registered consulting company provides $10,000 worth of standard-rated consulting services.
Its invoice may show:
Consulting services: $10,000
GST at 9%: $900
Total payable: $10,900
The $900 represents output GST collected from the customer.
The company subsequently accounts for its GST through its GST return.
A non-GST-registered company does not operate in the same way.
Can a Non-GST Registered Business Charge 9% GST?
Generally, no.
If ABC Pte Ltd is not GST-registered and provides consulting services worth $10,000, it should not simply issue an invoice showing:
Consulting fee: $10,000
GST 9%: $900
Total: $10,900
as though it were collecting Singapore GST.
A non-GST-registered company generally has no authority to collect that $900 as GST.
The appropriate invoice would ordinarily show the agreed selling price without representing any additional amount as Singapore GST.
Why Can’t a Non-GST Registered Company Charge GST?
GST-registered businesses effectively collect GST as part of Singapore’s tax system.
When a GST-registered business collects output GST from customers, that GST needs to be accounted for to IRAS.
Registration also creates various responsibilities.
A GST-registered business generally needs to:
- Charge GST correctly
- Maintain appropriate GST records
- Account for output tax
- Submit GST returns
- Pay GST due to IRAS
- Properly support input tax claims
- Maintain the necessary business and accounting records
A non-GST-registered company is outside this ordinary GST collection mechanism.
It cannot simply collect money from customers and label it “GST”.
What If My Customer Is GST-Registered?
This does not change the basic answer.
Suppose your company is not GST-registered, but your customer is a large multinational corporation that is GST-registered.
You still cannot simply add 9% GST to your invoice.
Your GST status and your customer’s GST status are separate issues.
For example:
Supplier: ABC Consulting Pte Ltd — Not GST-registered
Customer: XYZ Pte Ltd — GST-registered
Service fee: $10,000
ABC cannot simply add $900 of GST because XYZ happens to be GST-registered.
This is important because a GST-registered customer normally needs appropriate supporting documentation before claiming input tax.
If the supplier is not GST-registered and was not authorised to charge GST, the customer should not treat the wrongly labelled amount as ordinary claimable input GST.
What If My Suppliers Charge Me GST?
This is another common source of confusion.
Imagine that your company is not GST-registered.
You purchase a laptop from a GST-registered supplier:
Laptop: $2,000
GST: $180
Total: $2,180
You then provide services to your client.
Some business owners may think:
“I paid GST, so I should charge GST to my customer.”
That is not how the GST system works.
If you are not GST-registered, you generally cannot claim the $180 as input tax through a GST return.
However, that does not give you the right to charge your customer $180 or another amount and describe it as GST.
For accounting purposes, the GST you cannot recover will generally form part of the relevant cost or expense, depending on the transaction.
Can I Increase My Price by 9% Instead?
This requires an important distinction between pricing and charging GST.
A business is generally free to determine its commercial selling price, subject of course to contractual, consumer protection and other applicable requirements.
Suppose you previously charged:
$10,000
You may commercially decide that your new price is:
$10,900
The issue is how the amount is represented.
If you are not GST-registered, you should not describe the additional $900 as:
“GST 9%”
or represent yourself as collecting Singapore GST.
Instead, your selling price is simply $10,900.
For example:
Professional services: $10,900
That is fundamentally different from:
Professional services: $10,000
GST 9%: $900
Total: $10,900
In the first example, $10,900 is your selling price.
In the second example, you are representing $900 as GST.
A non-GST-registered business generally cannot do the latter.
Can I Put “GST Inclusive” on My Invoice If I Am Not GST-Registered?
Businesses should avoid wording that falsely suggests that Singapore GST has been charged.
If your company is not GST-registered, the invoice should not represent part of the amount as GST collected by your business.
Clear invoicing reduces the possibility of confusing customers.
If necessary, a business may state that it is not GST-registered, rather than presenting its price as including GST collected by the company.
What Happens If a Non-GST Registered Company Charges GST?
Wrongfully collecting GST is a serious matter.
IRAS specifically provides a voluntary disclosure procedure for businesses that have charged GST while they were not GST-registered.
A business that has wrongfully collected GST should not simply keep the additional money.
IRAS requires affected businesses making a voluntary disclosure to prepare information concerning the transactions, including invoice details and GST collected, submit the relevant voluntary disclosure form and pay the wrongfully collected GST amount to IRAS.
The precise consequences can depend on the facts and circumstances.
Therefore, if your company discovers that it has been charging GST despite not being GST-registered, the issue should be addressed promptly rather than ignored.
Example of Wrongfully Charging GST
Suppose ABC Marketing Pte Ltd is not GST-registered.
During the year it issues 100 invoices.
Each invoice is:
Marketing services: $1,000
GST 9%: $90
Total: $1,090
ABC therefore collects:
100 × $90 = $9,000
which it describes as GST.
The company cannot simply treat that $9,000 as additional profit.
It has represented the amount to customers as Singapore GST despite not being GST-registered.
The business should investigate the error and follow the appropriate IRAS process for wrongful GST collection.
Can I Charge GST While Waiting for My GST Registration Application?
Generally, you should not start charging GST merely because you have submitted an application.
The important date is the effective date of GST registration.
If you have submitted an application but your registration is not yet effective, you should not automatically assume that you can start adding 9% GST to invoices.
Once IRAS approves the registration, the approval letter specifies the effective date of registration and GST registration number.
The business generally starts charging and accounting for GST according to the applicable rules from its effective registration date.
Example: GST Registration Starts Next Month
Suppose ABC Pte Ltd receives confirmation that its effective GST registration date will be:
1 October
The company issues an ordinary invoice for services supplied on 15 September, with the relevant time of supply falling before registration.
The company should not simply add GST because it knows it will become GST-registered on 1 October.
For transactions around the effective registration date, however, businesses need to pay attention to Singapore’s GST time-of-supply rules.
Transactions that straddle the registration date can require more careful treatment.
For example, services might be performed before registration while the invoice is issued or payment received afterwards.
IRAS has specific rules addressing such situations.
Therefore, companies transitioning into GST registration should review transactions around their registration date carefully.
When Does a Company Need to Register for GST?
A Singapore business may need to register for GST when it becomes liable for compulsory registration.
One important threshold is S$1 million in taxable turnover.
Businesses should not assume, however, that GST registration only matters after historical revenue has already exceeded $1 million.
Singapore’s GST registration framework includes both retrospective and prospective considerations.
Businesses approaching the threshold should therefore monitor their taxable turnover rather than waiting until year-end.
Other GST registration regimes can also apply in particular circumstances, including rules involving imported services, overseas vendors and low-value goods.
What Happens If I Should Have Registered but Didn’t?
This is different from a business that legitimately remains below the GST registration threshold.
Suppose a company becomes liable for GST registration but fails to register.
IRAS may backdate the company’s effective registration date to when it should have been registered.
This can create a significant financial problem.
The company may have to account for GST on past sales from the effective registration date even if it did not actually collect the GST from customers.
Consider a simplified example.
A company should have been GST-registered and should have charged:
Sale price: $100,000
GST: $9,000
But because it failed to register, it only collected $100,000 from customers.
Depending on the applicable treatment, the company may still have to account for GST for the backdated registration period.
This can potentially mean funding the GST from its own cash resources.
Late registration can therefore be considerably more expensive than registering when required.
Can a Company Voluntarily Register for GST?
Yes, subject to IRAS requirements.
A business that does not yet meet the compulsory GST registration threshold may consider applying for voluntary GST registration.
There can be commercial reasons for doing so.
For example, voluntary registration may be worth considering where:
- The business incurs substantial GST on purchases
- Most customers are GST-registered businesses
- The company expects rapid growth
- The business imports substantial goods
- GST recovery is commercially significant
However, voluntary registration also creates additional responsibilities.
A business should therefore not register solely because it wants to put “GST” on invoices.
The administrative and commercial implications should be considered.
B2B Businesses and Voluntary GST Registration
Voluntary GST registration can sometimes be more commercially manageable for a B2B business.
Suppose your customers are mainly GST-registered corporations.
Before registration:
Selling price: $10,000
After registration:
Price: $10,000
GST: $900
Total: $10,900
If the customer is entitled to fully claim the $900 as input tax, the GST may have less impact on the customer’s effective cost.
Meanwhile, your business may be able to claim qualifying input tax incurred on its own business expenses.
This can make voluntary registration worth analysing for certain B2B businesses.
B2C Businesses and GST Registration
The situation may be different for businesses selling primarily to consumers.
Suppose a restaurant charges customers $100 before becoming GST-registered.
After registration, it needs to account for GST.
If market competition means customers will still only pay $100, the business may need to absorb the GST within the $100 selling price.
This can reduce its margin.
Alternatively, increasing the final price may affect competitiveness.
IRAS specifically identifies customer profile as one factor businesses should consider before voluntarily registering for GST.
Can a Non-GST Registered Company Claim GST?
Generally, no.
Just as a non-GST-registered company cannot ordinarily charge GST, it generally cannot claim input GST through a GST return.
Suppose the business pays:
Office rental: $10,000
GST: $900
Total: $10,900
If the company is not GST-registered, it generally cannot claim the $900 as input tax in the same way that a GST-registered company potentially could.
The GST therefore becomes part of the company’s cost.
How Should a Non-GST Registered Company Account for GST Paid?
For a non-GST-registered company, GST incurred on purchases will generally form part of the cost of the expense or asset because the GST is not recoverable as input tax.
For example:
Accounting services: $2,000
GST: $180
Total invoice: $2,180
A non-GST-registered company may generally record:
Debit: Accounting Expense — $2,180
Credit: Accounts Payable / Bank — $2,180
By comparison, a GST-registered company entitled to claim the full GST might generally separate:
Accounting Expense: $2,000
Recoverable Input GST: $180
Accounts Payable: $2,180
This is one of the major accounting differences between GST-registered and non-GST-registered companies.
How Should a Non-GST Registered Company Record Its Sales?
Suppose a non-GST-registered company provides consulting services for $10,000.
A simplified accounting entry might be:
Debit: Accounts Receivable — $10,000
Credit: Consulting Revenue — $10,000
There is no separate output GST account because the company is not charging GST.
If the company commercially sets its service fee at $10,900 instead, then the entire $10,900 is generally its revenue before considering other accounting adjustments.
The company should not artificially separate $900 and label it GST if it is not GST-registered.
What If My Customer Asks Me to Charge GST?
Your customer’s request does not give your company authority to charge GST.
Sometimes an accounts department may assume every Singapore supplier should provide a tax invoice containing GST.
That is incorrect.
Not every Singapore company is GST-registered.
If your customer asks:
“Where is the GST?”
you can explain that your company is not GST-registered and therefore does not charge GST.
A GST-registered customer cannot require an unregistered supplier to invent a GST charge merely so the customer can claim input tax.
Can Customers Check Whether My Company Is GST-Registered?
Yes.
IRAS provides a GST-registered business search facility.
Customers can check whether a business is GST-registered.
This means businesses should not assume that incorrectly charging GST will go unnoticed.
Corporate customers with experienced finance departments may also check suppliers’ GST registration status before accepting tax invoices or claiming input tax.
What If I Accidentally Charged GST?
If your business discovers that it has wrongfully charged GST while not GST-registered, do not simply ignore the issue.
IRAS has a specific Voluntary Disclosure for Wrongful Collection of GST process.
IRAS instructs businesses making such a disclosure to prepare:
- A summary of affected sales transactions
- Invoice numbers
- Invoice dates
- Value of sales
- GST collected
- A sample affected invoice
The business should then submit the relevant voluntary disclosure documentation and pay the GST amount wrongfully collected to IRAS.
Businesses facing this situation should consider obtaining professional tax advice, particularly where the error involves many transactions or substantial amounts.
Is Wrongful GST Collection an Offence?
Unauthorised GST collection can have serious consequences.
IRAS has previously prosecuted cases involving businesses that were not GST-registered but charged customers GST.
In a published prosecution case, IRAS stated that offenders can face a penalty of three times the amount of tax unlawfully collected, together with a fine of up to $10,000 for each offence.
The precise legal consequences in any current case depend on the applicable law and facts, but the important point for businesses is straightforward:
Do not charge GST unless your business is authorised to do so.
Are There Any Exceptions?
There are limited statutory situations where a non-GST-registered person may be required to account for GST.
IRAS identifies one example involving a non-GST-registered third party—such as a mortgagee, financier or auctioneer—selling or renting a GST-registered business’s assets in satisfaction of a debt.
This is a specialised situation.
It does not mean an ordinary non-GST-registered business can voluntarily add 9% GST to its normal invoices.
For most SMEs asking whether they can charge GST on ordinary sales to customers, the answer remains no until they are GST-registered and the relevant supply is subject to GST.
Common GST Mistakes Made by Singapore SMEs
Several misunderstandings occur repeatedly.
“My Supplier Charged Me GST, So I Can Charge My Customer GST”
Incorrect.
Your supplier’s GST registration status does not determine your GST registration status.
“My Customer Is GST-Registered, So I Should Add GST”
Incorrect.
Your customer’s registration does not authorise you to collect GST.
“I Applied for GST Registration Yesterday, So I Can Start Charging Today”
Not necessarily.
You should generally start charging GST according to your effective GST registration date.
“I’ll Collect GST Now and Register Later”
This is not the correct approach.
A business should not wrongfully collect GST before it is authorised to do so.
“If I Don’t Call It GST, I Can’t Increase My Price by 9%”
Incorrect.
Commercial pricing and GST are different concepts.
You may set your selling price according to your commercial arrangements, but you should not falsely represent part of that price as Singapore GST.
Frequently Asked Questions
Can a Non-GST Registered Company Charge GST in Singapore?
Generally, no. Only GST-registered businesses are allowed to charge and collect GST on their supplies from their effective registration date.
Can I Add 9% to My Invoice If I Am Not GST-Registered?
You may determine your commercial selling price, but you cannot represent an additional amount as 9% Singapore GST when you are not authorised to charge GST.
Can I Charge GST If My Customer Is GST-Registered?
No. Your customer’s GST registration does not authorise your company to charge GST.
Can I Charge GST Because My Suppliers Charge Me GST?
No.
A non-GST-registered business generally bears GST incurred on its purchases as part of its cost. Paying GST to suppliers does not give the business authority to collect GST from its own customers.
Can a Non-GST Registered Company Claim Input GST?
Generally, no. Input tax recovery is generally available to GST-registered businesses subject to the applicable conditions.
When Can I Start Charging GST After Registration?
You should generally start charging GST from the effective date of GST registration stated by IRAS, subject to the applicable time-of-supply rules.
What Is the Current GST Rate in Singapore?
Singapore’s prevailing GST rate is 9%.
What Should I Do If I Accidentally Charged GST?
Review the affected transactions promptly. IRAS provides a voluntary disclosure process specifically for businesses that wrongfully collected GST while not registered.
Can a Non-GST Registered Company Charge GST? The Bottom Line
For most Singapore businesses, the rule is simple:
If your company is not GST-registered, you generally cannot charge or collect GST from your clients.
It does not matter whether:
Your client is GST-registered.
Your suppliers charge you GST.
You expect to register for GST soon.
You have submitted a GST registration application.
Or you would prefer to separately recover the GST you incur on your business expenses.
Until your business is GST-registered and the relevant effective date and GST rules apply, you should not represent part of your customer’s invoice as Singapore GST.
However, this does not prevent a business from setting its own commercial price.
For example, a non-GST-registered company can charge $10,900 for a service if that is its agreed selling price.
What it generally cannot do is say:
Service: $10,000
GST 9%: $900
because this represents the $900 as GST.
Businesses should also monitor whether they are approaching the compulsory GST registration threshold. IRAS states that businesses must register when their taxable turnover exceeds the applicable S$1 million threshold under the registration rules.
Waiting too long can be costly because a late registrant can have its GST registration backdated and may have to account for GST on previous sales even if it did not collect the GST from customers.
Companies below the compulsory threshold can also consider voluntary GST registration where doing so makes commercial sense, particularly where the business incurs substantial input GST or primarily serves GST-registered B2B customers.
For Singapore SMEs, proper GST treatment should therefore form part of the company’s overall accounting and tax compliance processes.
Koh Management Pte Ltd provides accounting, bookkeeping, GST and tax support for Singapore businesses, together with corporate secretarial and company incorporation services.
Whether your company is currently GST-registered, approaching the registration threshold or considering voluntary registration, maintaining accurate accounting records can help you monitor taxable turnover, identify GST obligations and ensure that GST is charged only when the business is authorised and required to do so.
The key principle remains straightforward:
A non-GST-registered company should not charge its customers GST simply because GST is 9% in Singapore. GST can generally only be charged once the business is GST-registered and according to the applicable GST rules.