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Tax Differences Between an Australian and a Singapore Company

  • Koh Management
  • Oct 7
  • 7 min read

When businesses in Australia look to expand internationally or restructure for efficiency, Singapore often stands out as a prime destination. One of the main reasons is the stark contrast between the tax systems of Australia and Singapore. While both countries are economically advanced, their approaches to corporate taxation, personal income tax, and incentives differ greatly.

This article explores these key tax differences, explaining how Singapore’s tax framework supports business growth and why many Australian companies choose to set up their regional headquarters in Singapore.


1. Overview of the Tax Systems

Australia: A Comprehensive Tax System

Australia operates a residence-based taxation system, which means companies and individuals who are residents of Australia are generally taxed on their worldwide income. The Australian Taxation Office (ATO) enforces detailed compliance and reporting requirements, and the system includes both federal and state-level taxes.

This structure aims to maintain fairness and redistribute wealth but can also result in higher overall tax burdens and more complex compliance for businesses.

Singapore: A Territorial Tax System

Singapore, by contrast, uses a territorial tax system, meaning that only income earned or received in Singapore is taxed. Foreign-sourced income is exempt from tax unless it is brought into Singapore and does not meet certain conditions.

This approach provides a more business-friendly environment, especially for multinational companies that operate across several countries.


2. Corporate Tax Rates

Australia: 25% to 30%

As of 2025, Australia has two main corporate tax rates:

  • 25% for base rate entities (companies with an annual turnover under AUD 50 million and deriving no more than 80% of their income from passive sources)

  • 30% for all other companies

These rates are relatively high compared to global standards, making Australia one of the higher-tax jurisdictions in the Asia-Pacific region.

Singapore: 17%

Singapore’s headline corporate income tax rate is 17%, one of the lowest among developed economies. However, effective rates are often much lower due to various tax exemption schemes such as:

  • Start-Up Tax Exemption (SUTE): 75% exemption on the first SGD 100,000 of chargeable income and 50% on the next SGD 100,000 for the first three years.

  • Partial Tax Exemption (PTE): 75% exemption on the first SGD 10,000 and 50% on the next SGD 190,000 for all companies.

As a result, many small and medium-sized enterprises (SMEs) in Singapore pay an effective tax rate between 8% to 13% — significantly lower than in Australia.


3. Tax on Dividends and Profit Distribution

Australia: Imputation System

Australia uses an imputation system, where dividends distributed by companies carry franking credits representing the tax already paid at the corporate level. Shareholders can use these credits to offset their personal tax liabilities.

While this avoids double taxation, it also means that profits remain fully taxed at both company and shareholder levels unless offset by franking credits. Moreover, if the recipient is a non-resident, the franking credits may not always apply, and withholding tax could still be imposed.

Singapore: One-Tier Corporate Tax System

Singapore follows a one-tier corporate tax system, which means that once profits are taxed at the corporate level, dividends distributed to shareholders are completely tax-free, whether local or foreign.

This structure eliminates double taxation, encourages reinvestment, and provides a cleaner and simpler framework for profit repatriation to foreign shareholders — a major advantage for Australian companies with Singapore subsidiaries.

4. Capital Gains Tax

Australia: Taxable

In Australia, capital gains are treated as part of taxable income. Companies must pay tax on the net capital gain, which is the difference between the cost base and the selling price of an asset. Individual taxpayers may receive a 50% discount if the asset is held for over 12 months, but this does not apply to corporations.

This can significantly increase the cost of business restructuring, selling subsidiaries, or transferring ownership interests.

Singapore: No Capital Gains Tax

Singapore does not impose capital gains tax. Profits derived from the sale of capital assets (e.g. shares, property, or business divisions) are generally not taxable unless the Inland Revenue Authority of Singapore (IRAS) deems the transaction to be of a trading nature.

This absence of capital gains tax is a major attraction for foreign investors and entrepreneurs who want flexibility in managing their investments or exiting ventures.

5. Goods and Services Tax (GST) vs. GST/VAT

Australia: 10% GST

Australia’s Goods and Services Tax (GST) is set at 10% and applies to most goods and services sold domestically. Businesses are required to register for GST if their annual turnover exceeds AUD 75,000, and must submit Business Activity Statements (BAS) regularly.

Singapore: 9% GST (as of 2024)

Singapore’s Goods and Services Tax (GST) is currently 9%, having increased from 8% in 2024. While slightly lower than Australia’s rate, Singapore’s GST system is known for its simplicity and efficiency. Compliance and filing are straightforward, and businesses can easily claim input tax credits on business expenses.

Both countries have similar GST frameworks, but Singapore’s overall compliance process is less burdensome and less costly.

6. Personal Income Tax for Company Directors and Employees

Australia: Progressive up to 45%

In Australia, individual income tax is progressive, with rates ranging from 0% to 45%, plus a 2% Medicare levy. High earners face some of the highest personal tax rates in the region. This can impact talent attraction and executive compensation for Australian-based companies.

Singapore: Progressive up to 22%

Singapore also uses a progressive personal income tax system, but rates are significantly lower — ranging from 0% to 22%. The lower personal tax rates make Singapore attractive for expatriates and senior executives, allowing companies to offer competitive net compensation packages without excessive costs.

Additionally, Singapore offers various tax residency and relief schemes to avoid double taxation and reduce the burden for foreigners employed in Singapore-based HQs.

7. Treatment of Foreign-Sourced Income

Australia: Worldwide Income

Australian companies are taxed on global income, including profits from overseas subsidiaries. While foreign income tax offsets may reduce double taxation, compliance is complex, and tax liabilities often remain high.

Singapore: Territorial Income

Singapore only taxes income earned or received in Singapore. Foreign income that remains offshore is not taxed unless it is remitted into Singapore and does not qualify for exemption under certain conditions.

This approach makes Singapore particularly suitable for multinational structures. For instance, an Australian parent company can set up a Singapore subsidiary to handle regional operations and enjoy tax efficiency while complying with international tax standards.

8. Double Taxation Agreements (DTA)

Both countries maintain extensive DTA networks to prevent income from being taxed twice.

  • Australia has more than 40 DTAs, including with Singapore.

  • Singapore has over 80 DTAs, covering most major economies.

The Singapore–Australia DTA provides relief through tax credits and exemptions for income such as business profits, dividends, interest, and royalties. This ensures that companies operating in both jurisdictions can minimize tax leakage.

For example:

  • Dividends paid by a Singapore subsidiary to an Australian parent company are exempt from further tax in Singapore.

  • In Australia, these dividends can often qualify for foreign income tax offsets.

This agreement makes cross-border operations smoother and more tax-efficient.

9. Incentives and Grants

Australia

Australia offers several tax incentives for R&D and innovation, such as the R&D Tax Incentive, which allows eligible companies to claim a tax offset for qualifying R&D expenditure. However, Australia’s incentive system tends to be narrower and more compliance-heavy.

Singapore

Singapore’s government actively promotes foreign investment and innovation through incentives such as:

  • Pioneer Incentive Scheme – corporate tax relief for introducing new technologies.

  • Development and Expansion Incentive (DEI) – reduced tax rates for expanding activities.

  • Global Trader Programme (GTP) – tax concessions for international trading activities.

  • R&D Tax Deductions – up to 250% deduction for qualifying R&D expenses.

  • Regional Headquarters Incentive – lower tax rates for companies managing Asia-Pacific operations from Singapore.

These incentives make Singapore one of the most pro-business tax jurisdictions in the world, supporting both startups and large corporations.

10. Compliance and Administrative Burden

Australia: Heavier and More Complex

Australian companies face multiple layers of tax administration — federal, state, and local. Businesses must deal with:

  • Income tax

  • GST

  • Payroll tax (state-based)

  • Superannuation contributions

  • Fringe Benefits Tax (FBT)

The compliance load is significant, with frequent reporting and auditing requirements.

Singapore: Simple and Efficient

Singapore’s tax system is streamlined and digital-first. Businesses typically deal with only two main tax authorities — ACRA (for business registration and filings) and IRAS (for taxation).

Annual filing is simple, and electronic submission systems make the process efficient. This efficiency reduces costs and allows business owners to focus on growth rather than administration.

11. Withholding Taxes

Australia

Australia imposes withholding taxes on payments to non-residents:

  • Dividends: 30% (reduced under DTA)

  • Interest: 10%

  • Royalties: 30% (reduced under DTA)

Singapore

Singapore’s withholding tax rates are lower and apply only to certain payments to non-residents:

  • Interest, commission, or royalties: 10% to 15%

  • Management or technical fees: 17%

Under the Singapore–Australia DTA, these rates can be further reduced, providing cross-border efficiency and cost savings for companies operating between the two nations.

12. Tax Residency Rules

Australia

A company is considered resident in Australia if:

  • It is incorporated in Australia, or

  • It carries on business in Australia and has either central management and control or voting power controlled by Australian residents.

Singapore

A company is resident in Singapore if control and management are exercised in Singapore — usually meaning that board meetings and strategic decisions are made there.This makes Singapore an attractive jurisdiction for companies wanting to structure regional operations with legitimate tax efficiency.

13. Summary of Key Differences

Category

Australia

Singapore

Corporate Tax Rate

25%–30%

17% (lower effective rate)

Tax System

Worldwide

Territorial

Dividend Tax

Franking system

No tax on dividends

Capital Gains Tax

Taxable

Not taxable

GST

10%

9%

Personal Tax (Top Rate)

45%

22%

Compliance

Complex

Simple

Incentives

Limited

Extensive

Withholding Tax

Up to 30%

Up to 15%

Double Taxation Agreement

Yes

Yes (with Australia)

14. Conclusion: Why the Differences Matter

The tax differences between Australia and Singapore go beyond rates — they reflect two distinct philosophies of taxation.

Australia prioritises revenue generation and equity through higher, comprehensive taxes and detailed compliance. Singapore, on the other hand, emphasises growth, investment, and competitiveness by maintaining a low, simple, and transparent system.

For Australian companies seeking international expansion, establishing a Singapore HQ offers tangible advantages:

  • Lower effective tax rates

  • No capital gains or dividend tax

  • Simpler compliance

  • Access to Asia’s fast-growing markets

  • Strong bilateral ties and DTAs

Singapore’s tax environment not only enhances profitability but also positions businesses for sustainable regional growth.

 
 
 

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