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KPMG's Singapore Budget 2013 proposals 

4 February 2013
Sustainable, long term business performance must centre on investments into ‘value creation’, and the brand equity this generates. Examples of these investments include those in branding, research and development and investments in intellectual property.

Recent Singapore Budgets have introduced measures to encourage more productivity and innovation with a concurrent reduction in the reliance on foreign labour.

Mr Tay Hong Beng, Head of Tax, KPMG in Singapore, says, “Looking to the medium and long term, creating competitive advantage by providing better products and services and identifying new niche areas or new markets will be driven by a focus on value creation.”

He added that given the focus on productivity in recent years, more can be done to promote innovation and the growth of innovative Singapore brands. KPMG’s 2013 wishlist therefore first addresses the theme of helping Singapore businesses grow their brand.

In all, the four key themes KPMG hopes to see in Budget 2013 this year are therefore:

I: Help enterprises to build trusted and reliable brands
II: Promoting innovation in Singapore
III: Positioning Singapore as a premier Asian business hub
IV: Encourage businesses to play a part in achieving social objectives


I: Help enterprises build trusted and reliable brands

Participants at a pre-Budget 2013 Forum organised by KPMG in October 2012 expressed the sentiment that while managing costs and improving productivity were important; value creation, as defined by branding and innovation, were more important to longer term business performance.

In all, 39 percent of participants polled at the pre-Budget 2013 forum wanted subsidies on costs related to branding and marketing expertise supporting longer term brand development.

Mr Tay says, “The value creation process can help businesses build sustainable competitive advantage by helping them build trusted and reliable brands. We therefore see the need for new schemes to support the growth of local brands as well as new tax incentives to help these enterprises enjoy tax benefits from the commercialisation of their brands.”

Here are selected proposals to promote local branding:

a) Allow companies to claim writing down allowances on the value of their brands to encourage more local companies to develop their own uniquely-Singapore brand by pursuing originality and value creation.

b) Introduce broad-based tax incentive schemes (similar to “Patent or Innovation Box” tax schemes in other countries) where companies can enjoy lower effective tax rates on their income derived from the commercialisation of their intellectual property such as brands and patents. These may include sales from associated products, fees from relevant services and licensing and franchising income.

c) Extend the writing down allowance for intellectual property rights (IPRs) claim to all businesses, regardless of whether there exists an active trade or business, to encourage more efforts at growing brands in Singapore.

d) Extend Productivity and Innovation Credit (PIC) benefits to brand building exercises when brand experts are hired to help a local enterprise build its brand.


II: Promoting innovation in Singapore

Looking beyond productivity, more measures can be done to encourage innovation. In all, 35 percent of participants at the pre-Budget Forum felt that innovation activities merited more Government support while 31 percent of all participants felt that existing productivity and innovation schemes should be less prescriptive.

“More should also be done to recognise the higher risks involved with undertaking innovation-related activities,” says Mr Tay, “Rationalising productivity and innovation incentive schemes and widening the scope of eligibility may encourage higher participation in these schemes. Extending the enhanced R&D tax deduction to R&D centres of multinational companies may also attract more corporate R&D laboratories to Singapore. These measures will go some way to helping Singapore attain its aim of reaching R&D spending at 3.5 percent of Gross Domestic Product by 2015.”

Key proposals are:

e) Increase the cash payout limit of eligible deductions in the PIC to recognise the higher risks and investments involved with undertaking innovation-related activities.

f) Administer the PIC as a tax credit scheme rather than just providing enhanced deductions to benefit smaller Singapore companies.

g) Widen the scope of permissible expenditures in the PIC to better reflect the resources required to undertake R&D and other innovative work.

h) Liberalise existing tax concessions to encourage greater private sector R&D. For example, by extending the enhanced R&D tax deductions to R&D centres of multinational corporations so that they remain in Singapore over the long term and form an important component of Singapore’s R&D ecosystem.


III. Positioning Singapore as a premier Asian business hub

The world faces rapidly aging populations in the developed economies, continuing troubled economies in the Eurozone and a still-recovering US market. These deep-rooted worries about future economic prospects have fuelled a shift of economic power towards Asia.

Mr Tay says, “In these highly challenging and competitive environment, Singapore must not abandon opportunities and must pave the way to become one of the most preferred centres for investment in Asia, if not the world.”

Representing opportunities for Singapore, these proposals are aimed at strengthening Singapore’s position as a premier Asian business hub.

i) Enhance Singapore's tax treaty network by updating older tax treaties with countries such as Thailand, Indonesia and Australia and expanding the network to new countries.

j) Establish tax-free zone in the ASEAN Economic Community by exempting all withholding taxes within ASEAN to encourage freer flow of capital and technology.

k) Strengthen strategically important industry sectors such as the financial and marine industry by reviewing and enhancing existing tax measures.

l) Provide more certainty of tax rules to enhance Singapore’s attractiveness. Budget 2012 introduced a very welcome change to provide certainty of tax treatment for disposals of equity investments. However, this concession is only available till 2017, and as such, there remains an element of uncertainty.

m) Implement measures to help businesses with rising costs by extending the SME cash rebates, amounting to up to $5,000 for Year of Assessment 2013, to help with business costs and inflationary pressures.


IV: Encourage businesses to play a part in achieving social objectives

Employers can play an important role in help the Government achieve some of its social objectives.

Mr Tay adds, “Much has been suggested for businesses in Singapore, but it is just as important that measures are taken to encourage the ‘rootedness’ of Singaporeans. Our suggestions this year include measures to help companies capitalise on and manage an ageing workforce, and to support the family unit.”

n) Introduce more measures to encourage individuals to work and excel by increasing the earned income relief by $5,000

o) Introduce more measures to support the family unit such as increasing spouse relief to $5,000 and extending the foreign maid levy relief to male taxpayers with a non-working spouse.

p) Encourage more retirement planning by expanding existing measures. Examples include removing the CPF contribution limit and enhancing the Supplementary Retirement Scheme (SRS) by removing the taxation upon withdrawal and raising the annual contributions caps.

q) Remove caps on tax deductions for medical expenses to make older workers more employable such as removing the current tax deduction cap for the medical expenses of these employees.

Details to these proposals and more are in the appendix.


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Appendix: Details to KPMG’s Budget 2013 proposals


I: Help enterprises build trusted and reliable brands

1. Patent box schemes.

In countries such as the Netherlands, Ireland and the United Kingdom, “patent-box” schemes exist for companies which have developed their own intellectual property. These companies can enjoy lower effective tax rates on their income derived from the commercialisation of their intellectual property. These may include sales from associated products, fees from relevant services and licensing and franchising income. To encourage high-value intellectual property exploitation activities from Singapore, a similar patent-box scheme should be introduced.

2. Writing down allowances for internally-generated brands.

If a company purchasing an established brand enjoys a tax benefit, it would seem logical that the same benefit should be enjoyed by the company which built the brand. To encourage more Singapore companies to develop their own uniquely-Singapore brand, the existing tax regime should be tweaked to acknowledge the value of locally grown brands. Allowing companies to claim writing down allowances on the value of their brands would go a long way in encouraging local companies to pursue originality and value creation.

Such a scheme would depart from usual government schemes where subsidies or tax benefits are based largely on what a company spends. This would recognise that building a successful brand is a culmination of ideas, efforts and resources of one company over a long period of time for which capturing expenditure information alone cannot express.

However, it is also important to have sufficient safeguards to discourage undeserving claims and so claims could be based on independent third-party valuations of a brand.

3. Extend writing down allowance on intellectual property rights (IPRs) claim to all businesses.

Currently writing down allowance on IPR may only be claimed where there is an "active" trade or business. This means that businesses that do not have an active trade cannot make a claim for writing down allowances on IPR. Further, for intellectual property management activities, it is unclear under what circumstances intellectual property management activities constitute an active trade. This could discourage efforts to grow brands from Singapore.

For example, there might not be any direct sale revenue from Singapore from a particular brand. If the Singapore company owning that brand licences that brand to an overseas company, the Singapore company may not be able to claim any writing down allowances on the brand if it is not regarded as conducting an active trade or business, even in the scenario that the brand was purchased from a third party, and neither would it be able to group relief the writing down allowances.

It is therefore proposed that writing down allowances on purchased and internally-generated IPRs be allowed to all businesses, regardless of whether an active trade or business exist. In addition, to allow more flexibility in merger and acquisition deals, where Singapore companies with IPRs are acquired rather than the IPRs, the writing down allowances should be extended to the acquired Singapore companies. Currently, the writing down allowances are only available to IPRs acquired.

4. Productivity and Innovation Credit (PIC) benefits for brand building exercises.

The PIC could be extended to brand building exercises, where firms engage brand consultants to assist to develop a brand strategy. Qualifying costs would include costs paid to consultants as well as manpower costs incurred by employees on the brand building exercise.

II: Promoting innovation in Singapore

5. Increase the cash payout limit.

The PIC allows companies to convert $100,000 of their eligible PIC deductions to cash, at a rate of 60 percent, per year. This cash payout limit should be increased to $600,000 (effectively $100,000 of eligible expenditure for each of the 6 categories of PIC activities), or alternatively, there should be separate cash payout limits for innovation-related activities such as purchase of intellectual property and research and development (R&D) (i.e. separate $100,000 cash payout limits each for R&D, investment in design, purchase and registration of intellectual property), in recognition that there are higher risks involved with undertaking innovation-related activities which may require more investment by companies. Further, the 3 employee condition should be scaled back to allow the PIC benefits to also be extended to one-man start-up companies. In particular, it is not uncommon for R&D activities to be undertaken in founder-owned businesses with no employees, and these types of companies are the ones that need the cash subsidies the most.

6. Convert the enhanced R&D deductions to a tax credit scheme.

Companies may be taxed at different tax rates. For example, due to the partial tax exemption, smaller companies may only pay tax at effective tax rates of less than 10 percent. This means that the PIC benefit to these companies would be significantly smaller than larger companies that will pay taxes at effective tax rates closer to 17 percent. This inadvertently skews the incentive towards larger companies, although the scheme is intended to benefit smaller companies more. Therefore, the PIC should be administered as a tax credit scheme (where expenditures are offset against tax payable) rather than an enhanced deduction scheme (where expenditures are offset against pre-tax income). Many countries have moved from an enhanced tax deduction scheme to a credit scheme, such as the United Kingdom (partially) and Australia.

7. Widen scope of expenditure.

The scope of expenditure under the PIC should be widened to better reflect the resources required to undertake R&D work. Currently the range of expenditure included is restrictive, and confined to manpower costs, consumables and outsourced R&D expenditure, where the R&D activities are undertaken in Singapore. For R&D, the eligible expenditure should include the following:

• direct overheads (such as utilities and premises)
• direct-use plant and machinery
• licence payments for use of software for R&D purposes.

In addition, manpower costs should be qualifying expenditure regardless of where the R&D is actually performed, as long as the personnel involved in the R&D activities are employees of the company. This is to recognise that parts of a R&D project may necessarily have to be performed outside Singapore, due to various reasons (such as on-site testing of innovative solutions which were developed in Singapore, supervision of on-site installation of large equipment or construction projects designed in Singapore, non-availability of certain testing facilities in Singapore).

8. Encourage greater private sector R&D.

Provide tax concessions to attract R&D centres to Singapore by extending the 150 percent enhanced R&D tax deduction to R&D centres of multinational companies. By extending the concession to such R&D centres, R&D centres may enjoy additional encouragement to remain in Singapore upon the expiry of their other incentives such as the grants under the R&D Incentive Scheme for Companies (RISC). It is important to retain such R&D centres in Singapore as these corporate R&D labs form an important component of Singapore’s R&D ecosystem.

9. Allow “automatic” S19B claims for economic interests in intellectual property.

Currently, costs related to purchases of intellectual property with legal and economic rights would be eligible for writing down allowances. However, where only economic rights are purchased, writing down allowances are given subject to negotiations with relevant authorities. To put Singapore on par with tax favoured intellectual property management jurisdictions, writing down allowances should be granted automatically to purchases of intellectual property with only economic rights.

10. To allow S19B claims on costs incurred by a company in acquiring IP which would be put to use by a contract manufacturer (in and outside Singapore).

As we encourage businesses to scale up the value chain, companies may acquire IP and hold it in a Singapore company due to the robust IP protection regime in Singapore. However, the IP may be for use by the company’s contract manufacturers which manufacture the products of the company using the IP, based on specifications and requirements of the Singapore company. As the IP are assets of the Singapore company and exploited by the Singapore company, it should be entitled to S19B claims. Currently, based on the provisions of S19B, it is not clear if such claims would be supported, although arguably, there are technical grounds to support such claims. To provide clarity on the availability of such claims would encourage businesses to acquire the IP through the Singapore company. This is akin to machinery of businesses being placed at contract manufacturers’ premises and put to use by the latter.

11. Extend the Land Intensification Allowance (LIA) to other sectors.

The LIA is currently largely confined to the manufacturing sector. However, businesses in other sectors, such as logistics and transportation, may invest in new premises or upgrade current premises to achieve higher productivity, and the sums involved can be substantial. The LIA should therefore be extended to all industrial sectors, for buildings built on land zoned for industrial use (i.e. Business 1, Business 2 and Business Park zones). This could be facilitated initially on a case-by-case basis.

III. Positioning Singapore as a premier Asian business hub

12. Enhance Singapore’s tax treaty network.

Singapore’s tax treaty network should be enhanced by updating old tax treaties (such as Thailand, Indonesia and Australia) and expanding the network with new countries. Hong Kong is fast gaining on Singapore in terms of the quality and quantity of their tax treaty network. On the other hand, Singapore’s recent treaty strategy appears focused on signing exchange of information agreements.

A balance has to be made between appeasing our treaty partners and expanding our treaty network and improving existing treaties. For example, Singapore’s tax treaties with Australia, Taiwan, Indonesia and Thailand should be updated urgently. Hong Kong’s tax treaties with Indonesia and Thailand have better provisions and may encourage investors to hold Thailand and Indonesian investments from Hong Kong.

Alternatively, negotiate mutual tax exemptions under bilateral or multilateral Free Trade Agreements.

13. Establish tax-free zone in the ASEAN Economic Community.

Exempt all withholding taxes within ASEAN to encourage freer flow of capital and technology. This would be similar to the approach under the European Community. This would further cement Singapore’s attractiveness as a base for investing into the rest of the ASEAN region, particularly with the rest of the world set to experience slow growth.

14. Liberalise the concession to regard gains from disposals of subsidiaries held for at least 2 years as capital gains

Budget 2012 introduced a very welcome change to provide certainty of tax treatment for disposals of equity investments. However, this is currently only applicable to a company that disposes of investments in ordinary shares of another company, but not to other vehicles such as REITs and insurers taxed under Section 26 of the Income Tax Act. Further, it only applies to disposals made during the period 1 June 2012 to 31 May 2017 (both dates inclusive). To enhance the effectiveness of this measure and provide more certainty to investors, the sunset date should be removed, and it should be extended to disposals by REITs and insurers taxed under S26.

15. Measures for the Financial Sector

Enhance the FSI - Fund Management Scheme by lowering the concessionary rate of tax from 10 percent to 5 percent
Currently, Singapore has a comprehensive set of tax exemption incentives for fund vehicles and fund managers. These incentives have gone a long way to attract the best funds and fund managers to set up fund and fund management businesses in Singapore. To encourage and attract more fund managers undertaking fund management activities and investment advisory services to set up their bases in Singapore, the government may wish to consider enhancing the concessionary rate of tax from 10 percent to 5 percent under the FSI – Fund Management Scheme. Such a positive move is vital to anchor Singapore as a global leading fund management hub.

Exemption of withholding tax on interest payments made under a bank syndication arrangement
Currently, interest payments made by a borrower to non-resident banks (without permanent establishments in Singapore) that participate in a loan syndication led by a bank in Singapore would attract interest withholding. This creates unnecessary compliance costs for the borrower and also erodes the commercial competitiveness of the arrangement, as most non-resident member banks of the syndication may factor the interest withholding cost into the arrangement (for instance, via gross-up clauses). To enhance the attractiveness of Singapore as a financial hub, we would recommend that all such interest payments should be free from Singapore withholding implications. This would also help to strengthen the country’s position as a centre of excellence for loan syndication.

Exempt qualifying Enhanced-Tier fund established outside of Singapore from the requirement to file a tax return in Singapore
Currently, a qualifying fund established outside of Singapore is required to file a tax return in Singapore even though it is exempt from Singapore income tax. This requirement to file a tax return should be lifted as it adds to the compliance costs and negates the attractiveness of the incentive.

Extend the qualifying activities under FSI scheme to S$ lending
Currently, lending must be in non-S$ before the interest income derived may be taxed at the concessionary rate of 10 percent under the FSI scheme. In order to encourage more banks to lend in S$ to local businesses for their expansion whether locally or abroad, it is appropriate to consider extending the qualifying activities under the FSI scheme to S$ lending.

This would encourage the lending activities for the banks in Singapore and may lead to lower borrowing costs for the local businesses.

Enhance tax alignment rules for Islamic Financing to include all Syariah-compliant financial instruments
Currently, only qualifying income derived from prescribed Islamic financial instruments are accorded tax concessions/exemptions so as to align their Singapore direct and indirect tax treatment with that of their conventional equivalents

To further stimulate the development of the local Islamic financing industry and close the competitive gap with Islamic hubs such as Malaysia, the above tax alignment rules should be extended to include all (and not cover only prescribed) Islamic financing instruments that are Syariah-compliant.

This will accord more upfront tax certainty and avoid the cumbersome and time-consuming process of seeking written guidance from the Singapore tax authorities on tax treatment of Islamic transactions that do not fall within the prescribed list.

16. Measures for REITs.

Extending existing concessions
Existing concessions for REITs are due to expire on 31 March 2015. The concessions should be reviewed in view of the upcoming sunset date.

Recognise tax residency for REITs under tax treaties
Currently, there is no concept of Singapore tax residency for REITs. IRAS typically does not issue Certificates of Residence for REITs in view that REITs are trusts and they may not be the beneficial owner of the income they receive. Technically, there may be exceptions where treaties provide for trusts (or their trustees) to be recognised for tax treaty purposes, but not many of Singapore’s tax treaties make such provision. As such, REITs may not be able to benefit from protection offered under the tax treaties concluded between Singapore and its tax treaty neighbours (such as reduced withholding taxes). In view thereof, to further promote Singapore as a listing destination for REITs, existing and new tax treaties should be negotiated to allow REITs (or trusts in general) to avail of the benefits under the treaties.

To review and extend regulation 104A to include Limited Liability Partnership (LLP
The person to whom a prescribed supply is made for the purposes of section 38(5) of the GST Act was reviewed and extended to include a special purpose vehicle (SPV) which is defined to include a company and a trust with effect from 1 January 2009.

Notwithstanding this, given that the REIT industry has evolved substantially over time, the investment vehicles utilised by the REITs for their property investment have widened to incorporate their specific need at that point in time. To this end, the LLP structure has been used as an SPV for indirect holding of the REITs’ properties which was not contemplated in 2009.

It is therefore proposed that the government review the current SPV structure prescribed under regulation 104A and extend it to include an LLP to be cognisant of the development of REITs.

17. Measures for Shipping Industry.

To extend the zero-rating of the supply (including the letting or hire) of qualifying ship parts
Zero-rating of the supply (including the letting on hire) of qualifying aircraft parts that are certified as airworthy by a specified person under section 21(3)(x) of the GST Act.

The zero-rating relief of qualifying aircraft parts was introduced on 1 April 2009 by way of Ministerial remission and was legislated with effect from 1 January 2010. The effect of this change is that zero-rating shall apply to sale and/or rental of aircraft parts regardless of its physical location and belonging status of the customer. The suppliers no longer need to maintain commercial transport evidence to prove that the aircraft parts have left Singapore.

The treatment recognises that aircraft parts are unique and have no alternative uses in Singapore apart from being fitted onto aircraft and that due to Singapore‘s limited airspace, most aircraft (whether commercial or private) are treated as internationally bound.

Having regard to the above, on the same token and rationale, such zero-rating should also be expanded to the supply including the letting on hire of qualifying ship parts.

Currently, the ship parts can only be zero-rated if the Comptroller is satisfied that the goods are, amongst others, for installation on a ship or a ship under construction. This has created substantial administrative efforts required on the part of the suppliers to ensure compliance with the specific requirement on the use of the parts supplied and export documentation.

As most parts supplied to ships located in Singapore are generally international in character, we would propose that the same provision for supply (including the letting or hire) of qualifying aircraft parts should be extended to qualifying ships parts to ease compliance for the industry.

18. To expand the list of Regulation 33 GST-exempt supplies to include the provision of inter-company loan.

Companies within a corporate group often support each other in terms of the operational needs and in this respect; the provision of interest-bearing inter-company loan is a common inter-company transaction. For the borrower company, borrowing from within the corporate group may result in a lower interest expense as compared to borrowing from the banks. As for the lender company, given the current low interest rates payable on fixed deposits, lending excess monies to related companies may also translate into a higher interest income receivable. Effectively, this is a win-win scenario for both the lender and borrower companies.

Currently, GST-registered businesses are not allowed to treat the provision of inter-company loan as incidental to its taxable business under regulation 33 of the GST (General) Regulations and as a result, the amount of allowable input tax may be reduced pursuant to the normal input tax claiming conditions.

Considering that the provision of inter-company loan is not actively undertaken by a company for investment purposes and in substance, the interest income arising from inter-company loans is akin to the interest income arising from deposits placed with financial institutions, coupled with the fact that the much time and efforts would be required to identify the residual input tax for the purposes of denying a portion of this from input tax claim, we propose that the provision of inter-company loan be included in regulation 33 of the GST (General) Regulations as a step towards managing business cost.

19. Review existing tax incentives to ensure continued relevance.

Regional Headquarters Incentive
The Regional Headquarters Incentive is an entry-level incentive to encourage companies that are new to Singapore to explore doing business in Singapore. If after experiencing Singapore, these companies decide to expand, they may apply for the International Headquarter Incentive which provides for tax rates of 10 percent or less, depending on the degree of economic spin-offs they can introduce into Singapore. However, the current regional Headquarter Incentive offers a 15 percent concessionary tax rate, which may not be beneficial at all in view that the corporate tax rate is 17 percent and the partial tax exemption reduces the effective tax rate to below 15 percent. Hence, the concessionary tax rate for the Regional Headquarters incentive should be reduced from 15 percent currently to 13 percent, to encourage medium-sized MNCs to invest into Singapore.

Global Trader Programme (GTP)
Liberalise the stringent requirement for meeting certain sales threshold, to attract more local and foreign companies to use Singapore as a trading hub, especially in view of the slower economic environment, the need to encourage more local companies to grow and the tax-sensitive nature of trading activities (since trading activities are highly mobile). This will encourage companies to use Singapore as a trading hub for all types of products, instead of moving to competitor countries such as Hong Kong, Dubai, Switzerland and Malaysia.

20. Tax deductions for capital-raising expenditures.

Businesses can grow organically or through mergers and acquisitions (M&A). With Budget 2011 addressing M&A issues, Budget 2013 could address organic growth issues. One way companies grow is by raising capital through a stock exchange listing. However, IPO costs can be very substantial. To support the growth of SMEs, a concession making listing expenses (including restructuring costs related to the listings) tax deductible could be introduced.

21. Implement measures to help businesses with rising costs.

The SME cash rebates, amounting to up to $5,000 for Year of Assessment 2012, should be extended to help with business costs and inflationary pressures. For Year of Assessment 2012, to qualify for the SME cash rebate, a company has to make CPF contributions for at least one employee who is not a shareholder. However, in a bid to control escalating staff costs, companies are relying on casual workers, such as family members, for whom no CPF contributions are made. It is such companies that need the SME cash rebates the most. In view of this, the one employee condition should be reviewed. Instead, the SME rebate could be restricted to Singapore enterprises with less than $10 million turnover.


IV: Measures for individuals and furthering social objectives

22. Encouraging individuals to work and excel by:
  • increasing the Earned Income Relief (EIR) and Handicapped EIR by $5,000 for all age groups

  • expanding the zero percent tax bracket from $20,000 to $30,000 to help the sandwiched class

  • making permanent the tax deduction of 2.5 times for donations.


23. Supporting the family unit by:
  • increasing spouse relief to $5,000

  • extending the foreign maid levy relief to male taxpayers with a non-working spouse and at least three dependent children aged 16 years and below

  • providing relief for qualified education expenses incurred for dependent children.

24. Encourage retirement planning by:
  • enhancing Life Insurance relief by removing the CPF contribution limit

  • enhancing the Supplementary Retirement Scheme (SRS) by removing the taxation upon withdrawal and raising the annual contributions caps. If the SRS is fine-tuned, there would be no need to liberalise Section 5 pension plans.


25. Liberalise Not Ordinarily Resident Scheme
Lower the 90-day minimum for overseas business travel to 75 days in the Not Ordinarily Resident (NOR) taxpayer scheme where time apportionment concessions can be enjoyed, and remove the five-year maximum NOR qualifying period. More expatriates now take on regional responsibilities and stay longer.


26. Remove cap on tax deductions for medical expenses.
Since the government is encouraging the hiring of older Singaporeans, the current tax deduction cap for medical expenses should be removed in relation to older employees (say above 50 years old).