Overseas Vendor Registration Regime

Remote services are defined as any services where, at the time of the performance of the service, there is no necessary connection between the physical location of the recipient and the place of physical performance.

Between 1 January 2020 and 31 December 2022, only imports of digital services were subject to GST under the OVR regime.

Digital services include services which are supplied over the internet or an electronic network and the nature of which renders their supply essentially automated with minimal or no human intervention, and impossible without the use of information technology.

From 1 January 2023, non-digital services which do not fall within the definition of digital services but are consumed or capable of being consumed regardless of where the physical performance of the services is carried out, fall within the definition of remote services.

Therefore, under the OVR regime, all B2C imported services, whether digital or non-digital, if supplied and received remotely, are regarded as remote services. Overseas vendors are no longer required to distinguish between digital services and non-digital services.

All remote services which are supplied by a GST-registered overseas vendor to a non-GST registered customer in Singapore are subject to GST under the OVR regime except for:

1. services that fall within the description of exempt supplies under the Fourth Schedule to the Goods and Services Tax Act 1993 (GST Act)
2. services that qualify for zero-rating under section 21(3) of the GST Act had the services been supplied by a taxable person belonging in Singapore, and 
3. services provided by the government of a jurisdiction outside Singapore, if the services are of a nature that fall within the description of non-taxable government supplies under the Schedule to the Goods and Services Tax (Non-taxable Public Agency Supplies) Order 2024.

Examples of remote services include:

• downloadable digital content (e.g. mobile applications, e-books and movies)
• subscription-based media (e.g. news, magazines, streaming of TV shows and music, and online gaming)
• software programs (e.g. software, drivers, website filters and firewalls), electronic data management services (e.g. website hosting, online data warehousing, file-sharing and cloud storage)
• support services performed remotely to arrange or facilitate transactions, which may not be digital in nature (e.g. commission, listing fees, service or booking fee charged to the suppliers or customers)
• professional services (e.g. investment advisory, brokerage services, legal, tax and accounting services)
• educational, professional membership and examination services (e.g. distance learning classes, online examinations to obtain professional certification, membership subscription to professional associations)
• personal services (e.g. online counselling, matchmaking and telemedicine services)
• supply of consultancy and advisory services (e.g. advertising and digital marketing consultancy services, data analysis and research services).

Low-value goods, referred to as “distantly taxable goods” in the GST Act, are goods which at the point of sale:

• are not dutiable goods, or are dutiable goods, but payment of the customs duty or excise duty chargeable on the goods is waived under section 11 of the Customs Act 1960
• are not exempt from GST
• are located outside Singapore and are to be delivered to Singapore via air or post, and
• have a value not exceeding the GST import relief threshold of S$400.

An electronic marketplace is defined by IRAS as a medium that:

1. allows the suppliers to make supplies available to customers, and
2. is operated by electronic means.

This includes marketplaces operated via a website, internet portal, gateway, distribution platform or any other types of electronic interface, but excludes payment processors or internet service providers.

A redeliverer is a person who arranges with the customer to:

1. deliver or facilitate the delivery of goods to Singapore, and
2. provide or facilitate the use of an address outside of Singapore for delivery of the goods, or
3. purchase or facilitate the purchase of the goods.

An overseas supplier, overseas electronic marketplace operator or overseas redeliverer shall be liable for GST registration under either the retrospective or prospective basis, if the following conditions are satisfied:

1. Retrospective Basis

Your global turnover and value of remote services and low-value goods made to non-GST registered customers in Singapore for a calendar year (i.e. 1 January to 31 December) exceed S$1 million and S$100,000 respectively.

As an exception, you will not be liable to register for GST if:

1. you are certain that your global turnover or value of remote services and low-value goods made to customers in Singapore will not exceed S$1 million and S$100,000 respectively in the next calendar year
2. the projection is lower due to specific circumstances, and
3. you have supporting documentation to support the projection.

2. Prospective Basis

At any time, there are reasonable grounds to believe that your global turnover and supplies made to customers in Singapore will be more than S$1 million and S$100,000 respectively.

To determine the registration thresholds as stated above, overseas electronic marketplace operators must sum up:

• the value of B2C supplies of remote services and low-value goods made by them directly to customers in Singapore, as well as
• the value of B2C supplies of remote services and low-value goods made to customers in Singapore by local and overseas suppliers through their marketplace.

Overseas redeliverers must sum up:

• the value of B2C low-value goods supplied by them to non-GST registered customers in Singapore, as well as
• the value of B2C low-value goods supplies made by local and overseas suppliers, for which they assist non-GST registered customers to purchase and/or deliver to Singapore.

If you are liable for GST registration, you are required to apply for GST registration within 30 days of:

• the end of the relevant calendar year under the retrospective basis, or
• the day you are liable for GST registration under the prospective basis.

The GST registration rules under the OVR regime may also apply to you.

You are liable for GST registration under the retrospective basis if your turnover for the calendar year is more than S$1 million, or under the prospective basis if you can reasonably expect your turnover in the next 12 months to be more than S$1 million.

Your turnover will include:

• the value of low-value goods supplied by you directly to non-GST registered customers in Singapore
• the value of remote services supplied on behalf of overseas suppliers through your marketplace to non-GST registered customers in Singapore
• the value of low-value goods supplied by overseas and local suppliers through your marketplace to non-GST registered customers in Singapore, and
• the value of any other taxable supplies made by you.

The GST registration rules under the OVR regime may also apply to you.

If you are regarded as the supplier of the low-value goods which you assist non-GST registered customers to purchase and/or deliver to Singapore, you are liable for GST registration under the retrospective basis if your turnover for the calendar year is more than S$1 million, or under the prospective basis if you can reasonably expect your turnover in the next 12 months to be more than S$1 million.

Your turnover will include:

• The value of low-value goods supplies made by local and overseas suppliers, for which you assist your non-GST registered customers to purchase and/or deliver to Singapore, and
• The value of any other taxable supplies made by you.

The GST registration rules under the OVR regime may also apply to you.

If you are a local supplier who makes direct sales of low-value goods warehoused overseas to customers who are not GST-registered in Singapore, you are liable for GST registration under the retrospective basis if your turnover for the calendar year is more than S$1 million, or under the prospective basis if you can reasonably expect your turnover in the next 12 months to be more than S$1 million.

Your turnover will include:

• the value of direct sales of low-value goods warehoused overseas to customers who are not GST-registered in Singapore, and
• the value of any other taxable supplies made by you.

Direct sales refer to goods that are supplied directly by local and overseas suppliers to customers who are not GST-registered in Singapore (e.g. through the supplier’s own website), instead of supplying the goods through an electronic marketplace or redeliverer.

If any of the following conditions are met, you shall be regarded as the supplier for remote services and low-value goods made through the marketplace on behalf of overseas suppliers:

1. The electronic marketplace authorises the charge to the customer
2. The electronic marketplace authorises the delivery of supply to the customer
3. The electronic marketplace sets the terms and conditions under which the supply is made
4. The documentation provided to the customer identifies the supply as made by the marketplace, and not the merchant, or
5. The electronic marketplace and the merchant contractually agree that the marketplace is liable for GST.

You will be regarded as the supplier of the low-value goods if:

1. no electronic marketplace operator is treated as the supplier of the goods
2. the supplier of the goods does not deliver or arrange the delivery of the goods to Singapore, and
3. you deliver or facilitate the delivery of the low-value goods to Singapore and do one or more of the following:

• provide or facilitate the use of an address outside of Singapore for delivery of the low-value goods
• purchase or facilitate the purchase of the low-value goods.

You must account for GST on all taxable supplies made by you.

In addition, you are required to charge and account for GST on:

• supplies of remote services made on behalf of the overseas suppliers, and
• supplies of low-value goods made on behalf of local and overseas suppliers

listed on your platform to non-GST registered customers in Singapore if you are regarded as the supplier of those remote services and low-value goods.

You must account for GST on all taxable supplies made by you.

In addition, you are required to charge and account for GST on the B2C supplies of low-value goods made to non-GST registered customers in Singapore if you are regarded as the supplier of those low-value goods.

The above applies to both a local and an overseas redeliverer.

The registration obligation must be monitored on an ongoing calendar year basis as well as any point in time when you reasonably expect to exceed the threshold to register.

If you make sales of remote services and low-value goods, it is important that your accounting system can determine a B2C transaction for the supply of remote services and low-value goods to customers in Singapore and monitor the value of those supplies.

If the customer is a corporate entity, the customer is treated as belonging in Singapore if:

1. it has a business establishment or fixed establishment only in Singapore, or
2. it has a business establishment or fixed establishment both in Singapore and outside Singapore and the services are most directly used or to be used by its establishment in Singapore, or
3. it does not have a business establishment or fixed establishment in any country but its usual place of residence (i.e. place of incorporation or place of legal constitution) is in Singapore.

If the customer is an individual, the customer is treated as belonging in Singapore if his usual place of residence is in Singapore. The customer’s “usual place of residence” is in Singapore if:

1. he resides in Singapore for a settled purpose, such as to pursue a course or study or due to employment, and
2. his stay in Singapore has some degree of continuity, apart from temporary or occasional absence, such that it forms part of the regular and habitual pattern of his life.

Generally, the residential address of an individual may be regarded as his usual place of residence.

IRAS acknowledges that transactions over the internet may have limited information available. Therefore, overseas vendors may use proxy indicators to determine the belonging status of customers by maintaining two pieces of non-conflicting evidence based on the following proxy categories:

1. Payment proxy (e.g. credit card information, bank account details)
2. Residence proxy (e.g. billing address, home address), or
3. Access proxy (e.g. mobile country code of SIM card, IP address, location of fixed land line through which the service is supplied).