Treatment of income for non-resident public entertainer

Taxable income subject to withholding tax

Gross income refers to both cash and non-cash payments and includes, but not limited to:

For artistes

• Artiste fees
• Allowances e.g. per diem
• Benefits-in-kind 

For sportsmen

• Match fees
• Prize money
• Tournament winnings
• Win bonuses
• Allowances e.g. per diem
• Benefits-in-kind
• Non-cash gifts/prizes exceeding $100

Income due and payable to non-resident public entertainer on or before 31 Oct 2022

Non-taxable income (not subject to withholding tax)

As a concession, the following benefits provided by the payer are not taxable:

• Accommodation (excluding value of food) for short-term engagement of 60 days or less in any calendar year; and
• Cost of airfare.

Where accommodation is provided for 61 days and above in a calendar year, the cost of accommodation for the entire stay is taxable.

Deductible expenses

Only expenses which are wholly and exclusively incurred by the non-resident public entertainer in the production of the Singapore-sourced income and which are not reimbursed by the payer are deductible against the gross income.

Concession on deductible expenses

As a concession, the following costs incurred by the non-resident public entertainer are deductible:

• Accommodation (excluding value of food) for short-term engagement of 60 days or less in any calendar year; and
• Cost of airfare.

Where the stay in Singapore is for 61 days and above in a calendar year, the cost of accommodation for the entire stay is not deductible.

Non-deductible expenses

• Private expenses (e.g. value of food and ground transfers to and from airport); and
• Expenses incurred to put the public entertainer in a position to earn the income (e.g. transport expenses incurred from hotel to venue of service and back).

Income due and payable to non-resident public entertainer on or after 1 Nov 2022

The above administrative concessions will be withdrawn for income due and payable to the non-resident public entertainer on or after 1 Nov 2022. With the withdrawal, the following rules apply:

Taxability of income

• Cost of airfare borne by the payer and cost of accommodation provided/reimbursed by the payer - Such income that is due and payable to the non-resident public entertainer from 1 Nov 2022 onwards will be taxable, regardless of the period of engagement in a calendar year.

Deductibility of expenses

• The costs of airfare and accommodation (excluding value of food) incurred by the non-resident public entertainer in respect of income due and payable on or after 1 Nov 2022 will be deductible against the gross income of the non-resident public entertainer, regardless of the period of engagement in a calendar year. This is provided that the following conditions are met:
  1. The non-resident public entertainer’s principal place of business is outside Singapore;
  2. The non-resident public entertainer was carrying on the same activity prior to his trip to Singapore; and
  3. The sole purpose of the non-resident entertainer’s trip to Singapore is to perform the services in Singapore.
• Only expenses which are wholly and exclusively incurred by the non-resident public entertainer in the production of the Singapore-sourced income, and not private or capital in nature, are tax deductible.
• Business expenses such as cost of ground transfers from and to airport and transport from hotel to venue of service and back are deductible against the gross income of the non-resident public entertainer;
• Private expenses such as value of food are not deductible.

FAQs

#1 Deduction of food and transport expenses

#2 Deduction of airfare and accommodation

#3 Non-cash gifts and prize money