新加坡的HQ叫我找出 “Withholding Tax on Equipment Rental and Services is how many percent？”
这个的付款是你们付给新加坡吗？
Section 107A of the Income Tax Act 1967 — Withholding Tax Legislation — Non-Resident Contractors
Rate of Withholding Tax
The rate of withholding tax is: (i) 15% of the service portion of the contract payments to a non-resident contractor, in respect of tax of the non-resident contractor, and (ii) 5% of the service portion of the contract payments in respect of tax of employees of the non-resident contractor.
The total rate of withholding tax is, therefore, 20% of the service portion of the contract payments made to a non-resident contractor.
以下是从Public Ruling No. 4/2005 — Withholding Tax on Special Classes of Income (PR 4/2005)找到的：
8. Rent or other payments for use of moveable property — paragraph [url=]4A(iii)[/url] of the ITA 8.1 Paragraph[url=]4A(iii)[/url] of the ITA consists of rents or other payments made for the use of any moveable property belonging to the non-resident person which include rents or other payments made for the use of oil rigs, boats, ships, cars, aircraft or other equipment. However, the following income does not fall within the scope of paragraph [url=]4A(iii)[/url] of the ITA or is exempted— (i) Freight charges
Freight charges paid to non-residents in respect of export of goods are not within the scope of paragraph [url=]4A(iii)[/url] of the ITA as freight charges are fees for the shipment of goods and not payments for the use of a moveable property; and (ii) Pooling arrangements
A non-resident deriving income under paragraph [url=]4A(iii)[/url] of the ITA consisting of payments made under an agreement or arrangement for participation in a pool by a company resident in Malaysia engaged in the business of transporting passengers or cargo by sea is specifically exempted from withholding tax under the Income Tax (Exemption) (No. 25) Order 1995 P.U. (A) 322/1995.
8.2 The following are activities falling within the scope of paragraph [url=]4A(iii)[/url] of the ITA: (i) Slot hire
Slot hire is where the hirer has exclusive use of a particular slot in a ship to the exclusion of others. Payments paid for slot hire are subject to a withholding tax at 10% on the gross amount. (ii) Leasing of ships
Where a ship is chartered, whether bare boat or with crew, the exclusive use of the ship means that the payments made to the non-resident owner of the ship fall within the ambit of paragraph [url=]4A(iii)[/url] of the ITA and are subject to a withholding tax at 10% on the gross receipt. (iii) Time charter
Time charter is where a ship is chartered for a specific time. Thus, if a ship is chartered, say for 3 years, withholding tax at 10% on the gross amount must be deducted from the payment or the charter fees paid in respect of the use of the ship. (iv) Voyage charter
Voyage charter is in respect of a particular voyage, say from Port A to Port B. If a ship is chartered in respect of a particular voyage, the charter fee received is subject to withholding tax at 10% on the gross fees.
还有找到的其它资料：
Reduced withholding tax rates on rents or other payments for the use of movable property under tax treaties with a Royalty Article• [url=]Bahrain[/url] 8%
• [url=]Belgium — Protocol 2010[/url]** 7%
• [url=]Bosnia and Herzegovina[/url]** 8%
• [url=]Germany 2010[/url] 7%
• [url=]Ireland[/url] 8%
• [url=]Lebanese Republic[/url] 8%
• [url=]Luxembourg[/url] 8%
• [url=]Namibia[/url] 8%
• [url=]Netherlands[/url] 8%
• [url=]Qatar[/url] 8%
• [url=]Saudi Arabia[/url] 8%
• [url=]Singapore[/url] 8%
• [url=]South Africa[/url] 5%
• [url=]Spain[/url] 7%
• [url=]Sweden[/url] 8%
• [url=]Thailand[/url] 5% (JDA1)
• [url=]United Kingdom[/url] 8%
这个witholding tax是很special的。建议你询问公司的tax agent.
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