Residency and tax in Singapore: passes, tax residence and home rules

A pass such as an Employment Pass, ONE Pass or permanent residence lets a person live in Singapore; tax residence, decided by IRAS mainly on days of presence or employment, decides where they are taxed and where CRS reports go. The two are separate tests, and neither ends obligations in a home country such as US citizenship-based taxation or UK inheritance tax for long-term residents. That is why residency and tax come first in the eight-step process, before insurance, private banking or trusts are arranged.

Applies to: Singapore, with reference notes for the US, UK and the Chinese mainland.

Two questions, two sets of rules

The immigration question is which pass or status allows each family member to live, work or invest in Singapore. The tax question is where each person and each entity is tax resident, which country taxes which income, and where financial institutions send account information under the Common Reporting Standard (CRS) and the US Foreign Account Tax Compliance Act (FATCA).

A person can be resident in two countries at once under domestic rules; a double tax agreement (DTA), where one exists, may then allocate taxing rights. Published pass and programme criteria are minimum conditions, not entitlements: approval is at the discretion of MOM or EDB.

Who regulates it

Several agencies are involved, and none of them looks at a family's position as a whole; home-country authorities such as the IRS, HMRC and the Chinese mainland's State Taxation Administration keep their own rules after a move.

What it solves and what it does not

What a Singapore residency and tax position can do

1. Give a lawful basis to live and work in Singapore. The EP has a minimum qualifying salary and a 40-point COMPASS test, with higher salaries for new applications from 1 January 2027; the ONE Pass requires a fixed monthly salary of at least S$30,000 (MOM, 2026). Current salary tables and application steps are on hnwi.sg.
2. Offer a PR route for qualifying investors. The GIP has three investment options decided at EDB's discretion; Option C involves a single family office and is applied for separately (see family office).
3. Establish Singapore tax residence and treaty access. A foreigner is generally treated as tax resident if they stayed or worked in Singapore for at least 183 days in the previous calendar year, or continuously for three consecutive years. A COR certifies residence for DTA claims; IRAS states applications are processed in 2 to 3 weeks. IRAS says Singapore has concluded DTAs, limited DTAs and exchange-of-information arrangements with around 100 jurisdictions (list updated 4 February 2026).

What it does not do

• It does not end tax obligations elsewhere (see key risks below), and it does not stop CRS and FATCA reporting, which follows the tax residence and citizenship a customer declares.
• It does not guarantee any pass, PR or tax outcome.

Typical structures

How Singapore treats common positions — a map of questions, not a recommendation.

The section 10L entry follows IRAS's e-Tax Guide of 8 December 2023 as summarised by DLA Piper (14 December 2023), a secondary source; confirm scope against the latest IRAS guidance.

Key risks

1. Treating a pass as tax residence. An EP holder arriving mid-year may not meet the 183-day test, while the home country may still treat them as resident.
2. Assuming "no estate duty" means no estate tax anywhere. Singapore removed estate duty for deaths on or after 15 February 2008 (IRAS). The IRS, however, requires a Form 706-NA return for a non-resident non-citizen whose US-situated assets exceed US$60,000; US corporate shares are US-situated, while life insurance proceeds on such a person's life are not. Singapore is not among the US estate and gift tax treaty countries (IRS, 2026).
3. Overlooking US citizenship in the family. US persons have FATCA and FBAR obligations; FBAR applies when foreign financial accounts exceed US$10,000 in aggregate at any time in the year, including cash-value insurance policies (FinCEN).
4. UK long-term residence. HMRC treats someone resident in the UK for at least 10 of the last 20 tax years as a long-term UK resident; from 6 April 2025, inheritance tax applies to their foreign assets owned outright, and they remain in scope for at least 3 and up to 10 tax years after leaving.
5. Chinese mainland rules. A person with a mainland domicile, or present for 183 days or more in a tax year, is a resident individual and must declare overseas income between 1 March and 30 June of the following year (MOF/STA Announcement No. 3 of 2020).
6. Inconsistent CRS self-certifications across banks, insurers and trustees, or failing to update them after a move. The Amended CRS applies from 1 January 2027, with exchanges expected from 2028 (IRAS).

Applies to: Singapore, US, UK, Chinese mainland. Obtain advice from a qualified tax adviser in each jurisdiction where you are, or may become, tax resident.

Professionals you will need

• Tax adviser in each relevant country – residence, exit and continuing obligations, DTA position.
• Singapore lawyer – property holding, trusts, wills, corporate structures; check via the Law Society of Singapore.
• Employer or applicant's adviser – prepares EP, ONE Pass or GIP applications; MOM or EDB decides.
• Bank, insurer and trustee compliance teams – collect CRS and FATCA self-certifications.
• Corporate service provider (CSP) – incorporates entities and keeps registers; registered with ACRA.

A Singapore tax adviser cannot confirm what the US, UK or mainland authorities will conclude, so the lead adviser should collect each country's written conclusions, check that they agree, and give the same facts to every institution collecting self-certifications (see the professional-collaboration model).

Five due-diligence questions

1. In which countries is each family member tax resident this year and next year, under each country's own rules — and has anyone tested the DTA tie-breaker?
2. Do the CRS and FATCA self-certifications given to every Singapore bank, insurer and trustee match that analysis, and who updates them after a move?
3. Does anyone in the family hold US citizenship or US-situs assets, or meet the UK 10-of-20-years test?
4. What does the home country require on departure — exit filings, continuing declarations of overseas income, or a tail period for inheritance tax?
5. If a company, trust or property purchase is planned, has the residence and ABSD position been checked before the structure is chosen?

The full list of ten residency and tax questions is in the due-diligence checklists, section F.

Where to go deeper

CRS is explained on hnw.sg (Chinese). On this site, scenarios works through UK-linked and US-connected families and the FAQ answers questions on remittances, section 10L and CRS. Thresholds change, so check the agency's current page before acting. If you need these points applied to your own circumstances, you can register your enquiry through the contact options on this site.