Moving your business from Australia to Singapore: 2026 tax

If you're an Australian founder, you've seen the headline numbers: 17% company tax in Singapore against 25% or 30% at home. The rate gap is real. It is also the least important part of the decision. We cover the Singapore side in detail and highlight the questions to take to an Australian tax adviser.

Here's the comparison as of October 2026: the rates, then the Australian rules that decide whether they apply to you.

Singapore vs Australia tax at a glance

Corporate tax: 17% versus 25% or 30%

Singapore's headline corporate rate is 17% for every company, local or foreign-owned. In Australia, a company with aggregated turnover under A$50 million and no more than 80% passive income is a base rate entity at 25%. Everyone else pays 30%.

Singapore's start-up and partial exemptions

1. Start-up Tax Exemption (SUTE): for the first three Years of Assessment, 75% of the first S$100,000 and 50% of the next S$100,000 of chargeable income is exempt (up to S$125,000 a year). The company must be Singapore tax-resident, with no more than 20 shareholders and at least one individual holding 10% or more. Investment holding and property development companies are excluded, as is a company wholly owned by an Australian Pty Ltd.
2. Partial Tax Exemption (PTE): from year four, or from day one where SUTE does not apply, 75% of the first S$10,000 and 50% of the next S$190,000 is exempt (up to S$102,500 a year).

For YA 2026, IRAS lists a 50% rebate of tax payable, capped at S$40,000 including a S$2,000 cash grant for companies that made CPF contributions in 2025 for at least one local employee who is not a shareholder-director. Rebates change each Budget, so plan without them.

What the same profit costs in each country

Here's the tax on the same profit (same number of dollars in each currency; Singapore after exemptions, before rebate).

Capital gains, dividends and personal income tax

Capital gains

Singapore has no capital gains tax, though IRAS can tax a gain as income where the asset was held for trading.

Australia taxes gains as income. Individuals get a 50% discount after 12 months; companies get none. An Australian resident selling shares in a Singapore company pays Australian CGT, even though Singapore charges nothing.

Dividends

Singapore's one-tier dividends carry no further tax or withholding, wherever the shareholder lives. Our dividend tax guide for Singapore shareholders has the detail.

The trap: an Australian resident receiving a Singapore dividend pays marginal-rate tax on all of it, with no franking credit and no offset for the Singapore company tax.

Personal income tax

Singapore's resident rates run from 0% to a top marginal rate of 24% above S$1 million: S$5,650 on S$100,000, S$21,150 on S$200,000.

Australia's 2026-27 resident rates are 15% from A$18,201, 30% from A$45,001, 37% from A$135,001 and 45% above A$190,000, plus the 2% Medicare levy: A$22,520 on A$100,000, A$59,870 on A$200,000.

The Australian rules that follow a founder to Singapore

Tax residency

Australia taxes residents on worldwide income. The ATO's residency page sets out four tests. Spending fewer than 183 days in Australia does not make you non-resident: under the domicile test you stay resident until your permanent home is outside Australia.

Central management and control

A foreign-incorporated company is Australian-resident if it carries on business in Australia with central management and control there. Under Taxation Ruling TR 2018/5, board-level decisions made in Australia count. A Pte Ltd whose sole director signs everything from a kitchen table in Melbourne is an Australian company taxed at 25% or 30%.

Singapore's test mirrors it: a company is Singapore tax-resident where control and management is exercised.

Permanent establishment

Under the treaty, a fixed place of business in Australia, or a person there who habitually concludes contracts for the company, creates a permanent establishment whose profit Australia taxes. A founder selling to Australian clients from a home office in Sydney is the textbook case.

CFC rules

Australia's controlled foreign company rules in Part X of the Income Tax Assessment Act 1936 can tax you on a Singapore company's profit before any dividend is paid. The company is a CFC if five or fewer Australians hold at least 50%, one holds at least 40%, or Australians have de facto control; tax falls on each resident holding 10% or more, counting associates. Singapore is an unlisted country, so the active income test decides: keep tainted passive income under 5% of gross turnover and trading profit waits until distributed; fail it and the passive income is attributed to you each year.

CGT event I1: the tax on leaving Australia

It's often loosely called a departure tax, but it has nothing to do with the passenger movement charge on your air ticket. The day you cease Australian residency, CGT event I1 treats you as having sold every asset that is not taxable Australian property at market value, including your shares in the business. A valuation dated at departure sets the gain. You can elect to defer, but the assets then stay in the Australian CGT net until sold, and the 50% discount does not accrue for non-resident periods after 8 May 2012.

The Singapore-Australia tax treaty and withholding rates

The Singapore-Australia tax treaty, signed in 1969 and updated by protocols and the Multilateral Instrument, caps withholding on dividends, interest and royalties and settles which country taxes a person or company both claim. The text is on Treasury's treaty list.

Singapore also withholds on service fees and non-resident director's fees; our withholding tax guide covers when a Singapore company must withhold.

A Singapore parent can receive an Australian subsidiary's dividends tax-free under the foreign-sourced income exemption, if it can show the income was taxed in Australia.

Setting up a company in Singapore vs Australia: directors, payroll and filing

Until someone holds an Employment Pass or EntrePass and lives here, you will need a nominee director, arranged through an ACRA-registered corporate service provider. A nominee meets the legal requirement but adds no substance. Our guide to registering a Singapore company as a foreigner covers the pass routes.

Moving your business from Australia to Singapore: the order that works

1. Model the exit with an Australian adviser first. CGT event I1 and CFC exposure depend on what you own the day you leave.
2. Decide who moves, and which company owns what. The usual structures are a Singapore company alone, a Singapore parent over the Australian Pty Ltd, or the reverse.
3. Incorporate with substance. Setting up a company in Singapore that holds up means registering the Singapore company with a registered office, a Singapore-based director with authority, board minutes kept here and contracts signed here.
4. Secure the pass. An Employment Pass through your own company (minimum S$5,600 a month, rising to S$6,000 from 1 January 2027, higher with age, plus the COMPASS points test) or an EntrePass; check MOM's criteria.
5. Move customers, IP and staff at market value. Moving contracts or IP out of the Australian company is a market-value disposal, and charges between the companies must be at arm's length.

Common mistakes Australian founders make

1. Assuming 183 days abroad ends residency. The domicile test can keep you resident; confirm your position with an Australian adviser before relying on Singapore rates.
2. Running the Pte Ltd from Australia. Hold and minute board meetings in Singapore, with a director here who has real authority.
3. Leaving without a valuation. CGT event I1 uses market value on the day you cease residency, so get your shares valued as at that date.
4. Parking investments or IP in the Singapore company. A services business usually passes the CFC active income test; a holding company usually does not.

Frequently asked questions

Is there a Singapore-Australia tax treaty?

Yes. The 1969 double taxation agreement, updated by protocols and the Multilateral Instrument, caps Australian withholding at 15% on dividends and 10% on interest and royalties paid to Singapore residents. It also sets tie-breaker rules for anyone both countries treat as resident.

Does a Singapore company cut my Australian tax if I stay in Australia?

Less than you expect. Australia still taxes your worldwide income, and a company run from Australia can become Australian-resident. Even if it stays Singapore-resident, CFC rules can attribute passive profit to you, and dividends are taxed at your marginal rate with no franking credit.

Is there an exit tax when I leave Australia for Singapore?

Yes. CGT event I1 treats you as selling your non-Australian assets, including shares in a foreign company, at market value on the day you cease residency. You can defer, but the assets then stay in Australia's CGT net.

Do I need to close my Australian company?

No. The Pty Ltd can keep trading, become a subsidiary of the Singapore company or be deregistered later. Even dormant, it owes the ASIC annual review fee, a tax return and a resident director.

Set up the Singapore side with a team that knows both

If Singapore is where the business is heading, our company incorporation service handles ACRA registration, the registered address, corporate secretary, Xero setup and first-year accounting and tax on one fixed monthly fee, refers you to a nominee director, and we will tell you plainly which questions belong with an Australian adviser. Book a free consultation and we will map the move with you.