Singapore: GST zero-rating for sales of exported goods

Can goods purportedly exported to Malaysia be zero-rated despite missing documents

Can goods purportedly exported to Malaysia be zero-rated despite missing documents

The Goods and Services Tax (GST) Board of Review—in a decision favourable to the trader—addressed the tax authority’s decision to deny zero-rating for exports of goods that were “hand-carried” by motor vehicle to customers in Malaysia.

The case is: GDY v. Comptroller of Goods and Services Tax [2021] SGGST 1 


The trader (involved in the wholesale trade of mobile phones, tablets, and related accessories) purchased goods from local and overseas suppliers and resold them to customers in and outside of Singapore.

The trader specifically sold the goods to Malaysian customers who collected them from the trader’s Singapore place of business and hand-carried the goods to Malaysia by motor vehicles.

The tax authority (after several audits of the trader’s sales) ultimately denied zero-rating on these sales on a finding that export permits were not properly maintained with regard to the declaration form and carrier’s vehicle number—documents required pursuant to an Inland Revenue Authority of Singapore guide (2009). The tax authority made a GST assessment of approximately S$27 million.

In response, the trader asserted that zero-rating was available for the disputed transactions because export documents objectively proved that the goods were exported out of Singapore and that the guide’s requirements had materially been complied with and further that the guide had been superseded by specific instructions from the tax authority which the trader had complied with.

At issue was whether the trader could rely on the specific directions from the tax authority (instead of the guide) to support the zero-rating of the sales of goods for export out of Singapore.

The Board of Review concluded that given that the trader had provided evidence supporting the actual export of the goods, the tax authority needed to take necessary steps to examine whether such exports had occurred—and not merely insist on the two missing documents (which could be explained because the specific directions from the tax authority were followed by the trader). In concluding, the Board did not find the tax authority had taken such steps and thus it could not conclude that there had been no export of the goods. 

Read a November 2021 report [PDF 444 KB] prepared by the KPMG member firm in Singapore


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