The short answer
- India asks for a tax residency certificate before it applies treaty rates. In Singapore that is the IRAS certificate of residence (COR).
- India also needs Form 41 on its e-filing portal. Form 41 replaced Form 10F when the Income-tax Act, 2025 took effect on 1 April 2026.
- IRAS issues a COR when control and management is exercised in Singapore.
- From 2025, foreign-owned investment holding companies also need a Singapore-based executive director who is not a nominee, a key employee, or a related Singapore manager.
Why you need it
Your Singapore company earns dividends, interest, royalties or service fees from India. The India-Singapore tax treaty can lower the Indian withholding tax on that income. To apply the lower rate, the Indian payer needs proof that the company is resident in Singapore. That proof is the COR.
What India asks for
- A tax residency certificate for the relevant period: the IRAS COR.
- Form 41, filed online on the Indian income tax portal. It replaced Form 10F under the Income-tax Act, 2025.
- The treaty claim itself now sits in section 159 of the new Act.
The IRAS test
A company is resident in Singapore when its control and management is exercised here, meaning where the board makes strategic decisions. IRAS looks at where meetings are held and where directors physically are when they decide.
The holding company trap. For certificates covering 2025 onwards, a foreign-owned investment holding company must show strategic decisions are made in Singapore and also meet one of these:
a Singapore-based executive director who is not a nominee; a Singapore-based key employee; or management by a related company based in Singapore. A nominee director on its own does not pass.
How to apply
- Confirm the company meets the test for the period you need.
- Apply online through the IRAS myTax Portal, using Corppass. See Corppass explained if you are unsure who has access.
- Answer IRAS questions on board meetings, directors and staff. Keep the evidence ready.
- Send the COR to the Indian payer, and file Form 41 in India.
- Diarise the renewal. Each COR covers a set period, usually a calendar year.
Your evidence file
- Board meetings held in Singapore, minutes signed here
- A Singapore director with real authority, or a key employee based here
- Bank mandates and contract signing controlled from Singapore
- No routine approvals by email from the Indian parent's office
The COR is the Singapore half of the story. India runs its own test on the same facts: read POEM and substance next.
What the certificate is worth
Without a COR and Form 41, the Indian payer applies Indian domestic withholding rates. With them, it applies the treaty rate. The difference is often large.
| Income from India | India-Singapore treaty rate | Without treaty relief |
|---|---|---|
| Royalties and fees for technical services | 10% | Typically 20%, plus surcharge and cess |
| Interest | 10% if paid to a bank or financial institution, otherwise 15% | Domestic rates, often higher |
| Dividends | 10% where the company holds at least 25% of the payer, otherwise 15% | Domestic rates |
On S$500,000 of annual royalties, the gap between 10% and an effective domestic rate above 21% is more than S$55,000 a year. Treaty rates also depend on the Singapore company being the beneficial owner of the income and passing the treaty's anti-abuse rules.
Timing that works
- Apply early in the calendar year for which the Indian payments will be made, so the payer has the COR before the first payment.
- A newly incorporated company can apply, but IRAS may ask more questions about where the board meets and who runs the business. Have the first board minutes ready.
- If the COR arrives after tax has been withheld at the higher rate, the Singapore company may be able to claim a refund in India by filing an Indian return. That is slower and costlier than getting the paperwork in place first.
Questions people ask
What does India need to apply treaty rates?
A tax residency certificate (the IRAS certificate of residence) and Form 41 on the Indian e-filing portal, which replaced Form 10F from 1 April 2026.
How do I apply for a certificate of residence?
Online through the IRAS myTax Portal, using Corppass. Each certificate covers a set period, usually a calendar year.
What withholding rate applies to royalties from India with a COR?
10% under the India-Singapore treaty for royalties and fees for technical services, provided the Singapore company is the beneficial owner and meets the treaty conditions. Without treaty relief the domestic rate is typically 20% plus surcharge and cess.
Talk it through with an adviser
Tell us your structure and deadlines. We reply with what applies to you and a fixed-fee proposal.
Sources
- IRAS: Applying for a certificate of residence
- KNAV: Tax residency certificate in Singapore (IRAS criteria) (secondary source)
- India Briefing: Form 41 and treaty relief under the Income-tax Act, 2025 (secondary source)
General information only, last reviewed 11 November 2026. It is not advice for your situation. Laws and practice change, and the official sources linked above prevail. Speak to a qualified adviser before you act. Northwise does not file with Indian authorities; India-side work is done by independent licensed firms.
