WT/TPR/S/267/Rev.1 Trade Policy Review 
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  IV. TRADE POLICIES BY SECTOR 
(1) MANUFACTURING  
1. Singapore's manufacturing sector accounted for 20.9% of GDP in 2011 (down from 24.1% in 
2007).  The Government's economic strategy is founded on a strong manufacturing base with an 
output target in the range of 20-25% of GDP and aims to achieve a further shift away from 
labour-intensive manufacturing towards high-value- added, capital-intensive industries.  The 
restructuring of the economy is driven by comp etition from low-cost producers in the region and 
Singapore's rising labour costs.  Singapore's labour productivity in manufacturing has been lagging compared with major competitors.  For example, its labour productivity level has been about one-third 
lower than in the United States.  One the main thrusts of the economic strategy therefore is to achieve 
productivity-led growth (Chapter I(4)).   
2. In 2010, the Economic Strategies Committee (ESC) submitted recommendations, and their 
key directions were adopted by the Government and implemented within the framework of the 2010 
and 2011 budgets.
1  The ESC's recommendations focus on ways  to enhance productivity as a basis for 
growth and competitiveness.  Singapore is looking  at increasing productivity growth from 1%, 
achieved annually during the last decade (1.4% in th e manufacturing sector), to an average of 2-3% 
per annum over the next decade.  To  achieve this, the Government plan s to deepen skills and expertise 
within every sector of the economy and encourag e businesses to expand abroad and capture new 
growth opportunities.  The ESC recommends a fu rther move into complex manufacturing where 
know-how and intellectual property are crucial, such  as nutriceuticals;  the design and production of 
medical device components;  and cross-disciplinary areas, for example bioelectronics.  The 
Committee also proposes assisting manufacturing-re lated services, such as headquarter-related 
activities, R&D, intellectual property management , and product lifecycle management, so as to 
capitalize on the convergence of manufacturing with services. 
3. The Government has launched a number of incentive schemes that emanate from the 
recommendations of the ESC.  The National Producti vity Fund, with a budget of S$2 billion over ten 
years, provides support to help enterprises improve productivity.  The Land Intensification Allowance 
scheme was introduced in 2010 to support the intensif ication of land use towards more land-efficient 
and higher-value-added activities (see also Chapter III(3 )(i)).  In order to reduce the growth of the 
foreign workforce and reallocate r esources towards investing in skills  of local and foreign employees, 
the foreign worker levy in the manufacturing sector  will be increased progressively over 2010 to 
2012.2 
4. The sectoral clusters in manufacturing that  are monitored annually by the Singapore 
Government are:  electronics, chemicals, biomedical sciences (comprising the pharmaceutical, medical technology, biotechnology, and healthcare service industries), and engineering (including 
precision and transport engineering).  After a severe downturn during the global financial crisis, the 
electronics industry has recovered and maintains its position as the largest industry (Table IV.1).  The 
transport engineering cluster has expanded strongly in recent years.  Its growth is attributable, 
inter  alia, to increased activity in shipbuilding, ship repair, and offshore conversion.  The production 
of oil rigs and production of oil-field equipment has also increased substantially to meet higher 
demand.  Singapore's aerospace industry has grown to  become the most comprehensive maintenance, 
                                                      
1 Ministry of Finance online information.  Viewed at:  http://app.mof.gov.sg/esc.aspx. 
2 For more information on foreign worker changes, see Ministry of Manpower online information.  
Viewed at:  http://www.mom.gov.sg/newsroom /Pages/PressReleasesDetail.aspx?listid=349. Singapore WT/TPR/S/267/Rev.1 
 Page 55 
 
 
  repair and overhaul hub in Asia.  Singapore's Jurong Island is among the world's top 10 petrochemical 
hubs.   
Table IV.1 
Employment, output and value-added manufac turing by industry cluster, 2007 and 2011 
(% and S$ billion) 
 Employment Total outputa Value addedb 
 2007 2011 2007 2011 2007 2011 
Electronics 23.5 19.6 30.6 30.2 29.7 29.2 
Semiconductors 10.5 10.3 16.0 17.3 17.6 17.9 
Computer peripherals 4.0 2.7 4.4 2.9 3.9 4.4 
Data storage 4.0 2.7 3.9 2.9 2.8 3.0 
Infocomms & consumer electronics 2.6 2.3 5.1 6.4 3.6 3.1 
Other electronic modules & 
components 2.5 1.7 1.1 0.6 1.7 0.8 
Chemicals 5.7 5.8 33.2 34.0 11.8 9.0 
Petroleum 0.8 0.9 19.0 19.2 4.1 0.5 
Petrochemicals 1.3 1.3 11.1 11.3 3.6 4.9 
Specialty chemicals 2.3 2.4 2.4 2.8 3.0 2.6 
Others 1.3 1.2 0.7 0.7 1.1 1.0 
Biomedical manufacturing 2.9 3.6 9.6 9.5 24.4 22.4 
Pharmaceuticals 1.0 1.4 8.4 8.0 21.8 19.3 
Medical technology 1.9 2.2 1.3 1.5 2.6 3.2 
Precision engineering 25.0 22.1 9.6 9.6 13.0 12.6 
Machinery & systems 8.8 10.0 4.2 5.7 5.7 7.2 
Precision modules & components 16.1 12.1 5.4 3.9 7.3 5.3 
Transport engineering 21.9 26.6 10.0 9.1 11.9 15.6 
Marine & offshore engineering 15.8 20.6 6.6 5.7 6.2 9.4 
Aerospace 4.6 4.6 2.7 2.8 4.9 5.1 
Land 1.5 1.5 0.7 0.7 0.8 1.0 
General manufacturing industries 21.0 22.2 7.0 7.6 9.2 11.3 
Printing 4.4 4.0 1.2 0.9 2.5 2.3 
Food, beverages & tobacco 5.4 6.3 2.3 2.9 2.4 3.9 
Miscellaneous industries 11.2 11.9 3.5 3.8 4.3 5.1 
Total manufacturing 100.0 
(404,057 
persons) 100.0 
(418,560 
persons) 100.0 
(S$253.4 
billion) 100.0 
(S$285.5 
billion) 100.0 
(S$56.0 
billion) 100.0 
(S$57.7
billion) 
a Total output includes manufacturing output (total value of all commodities produced (includi ng by-products) and industrial 
services rendered during the year) and other operating income. 
b Value added is total output less materials, utilities, fuel, tr ansportation charges, work give n out and other operating costs . 
c Preliminary. 
Note: Figures may not add up due to rounding. 
Source: Information from the  Economic Development Board. 
(2) SERVICES  
(i) Overview 
5. Services is the most important sector in terms of contribution to GDP and employment 
(Chapter I(1)).  In 2011, wholesale and retail trad e contributed 17.4% of GDP, followed by business 
services (14.1%), finance and insurance (11.9%), ot her service industries (11.4%), transportation and 
storage (8.2%), information and communicati on (3.6%), and accommodation and food services WT/TPR/S/267/Rev.1 Trade Policy Review 
Page 56 
  
  (2.4%).  During 2007-11, the fastest growing subsect ors were:  finance and insurance (7.1% average 
annual rate), other service industries (7%), business services (4.8%), accommodation and food 
services (4.1%), wholesale and retail trade (3.5%), and transportation and storage (1.7%).3 
6. Under the GATS, Singapore made commitments in 7 of the 12 sectors listed in the Services 
Sectoral Classification List (business services;  communication services;  construction services; 
financial services;  tourism and travel related servi ces;  recreational, cultural and sporting services; 
and transport services);  and in a total of 67 of the 156 subsectors.4  Singapore also participates in the 
Fourth Protocol to the GATS (basic telecommunications) and the Fifth Protocol (financial services).  Since the previous Review of Singapore, in 2007, th ere have been no changes to its commitments or 
its MFN exemptions.
5  Nonetheless, Singapore has offered to remove one of its MFN exemptions 
relating to financial services.  Singapore submitte d an initial conditional offer on services in the 
context of the DDA negotiations in July  2003 and a revised offer in May 2005.6   
7. Singapore also has services commitments unde r the ASEAN Framework Agreement on Trade 
in Services (AFAS), signed in December 1995 ( see Chapter II).  The AFAS aims to enhance 
cooperation in and substantially elim inate restrictions to trade in services among member states, with 
a view to realizing a free-trade area in services.7  ASEAN has concluded seven packages of AFAS 
commitments through five rounds of negotiations si nce January 1996.  In addition, there have been 
five packages of commitments in financial services a nd six on air transport.  Individual commitments 
contain horizontal and sector-specific commitments and MFN exemptions;  the latest package was signed in 2010.
8  
8. During the review period, Singapore remain ed active in negotiating and implementing 
preferential trading agreements, most of which in clude services provisions (Table II.2).  A positive-
list approach was followed in the ASEAN-Australia -New Zealand Free Trade Area;  the Agreement 
between ASEAN and Korea;  and the China-Singapo re Free Trade Agreement;  while a negative-list 
approach was adopted in the Peru-Singapore Free Trad e Agreement.  Overall, there is much diversity 
in Singapore's services commitments in its various preferential agreements.  In most cases, 
commitments go beyond the GATS schedule/offer. 
(ii) Financial services 
(a) Overview 
9. The structure of financial services institutions  in Singapore basically consists of banks, 
insurance companies, and other financial ins titutions including those dealing in securities 
(Table IV.2).  The Monetary Au thority of Singapore (MAS) supervi ses all financial institutions on the 
basis of the Monetary Authority of Singapore Act.  In general, the MAS allo ws financial institutions 
                                                      
3 Ministry of Trade and Industry (2012). 
4 WTO documents GATS/SC/76, 15 April 1994; GATS/SC/76/Suppl.1, 28 July 1995; 
GATS/SC/76/Suppl.1/Rev.1, 4 October 1995; GATS/SC/76 /Suppl.2, 11 April 1997; and GATS/SC/76/Suppl.3, 
26 February 1998. 
5 WTO document GATS/EL/76/Suppl.1, 28 July 1995. 
6 It includes an additional 23 sub-sectors in:  business services;  distribution services;  education 
services;  environmental services;  health-related and social services;  tourism;  and maritime transport services 
(WTO document TN/S/O/SGP/Rev.1, 6 June 2005). 
7 ASEAN Framework Agreement on Services (AFAS).  Viewed at:  http://www.aseansec.org/ 
6628.htm.   
8 The 8th Protocol to Implement the Packag e of Commitments under the AFAS. Singapore WT/TPR/S/267/Rev.1 
 Page 57 
 
 
  that are better able to manage their risks to ha ve greater business latitude, while supervising weaker 
ones more closely.9  It also administers, inter alia,  the Banking Act, the Finance Companies Act, the 
Securities & Futures Act, the Financial Advisers Act,  and the Insurance Act.  The Financial Industry 
Disputes Resolution Centre (FIDReC) is an independent one-stop service centre where consumers 
may seek help to resolve disputes with financial institutions.10 
Table IV.2 
Structure of financial services institutions, 2007-11 
Number (end-March of each year) 
 2007 2008 2009 2010 2011 
Banks 108 113 114 120 120 
Locala 5 6 6 7 6
Foreign 103 107 108 113 114
Full banks 24 24 27 25 26
Wholesale banksb 36 42 41 46 50
Offshore banks 43 41 40 42 38
(Banking offices including head offices and main offices) 399 408 409 421 428
Asian Currency Units  154 158 161 162 163
Banks 106 111 112 117 117
Merchant banks 48 47 49 45 46
Finance companies  3 3 3 3 3
(Finance companies' offices including  head offices) 39 39 39 39 39
Merchant banks 49 49 50 46 47
Insurance companies 153 151 158 158 157
Direct insurers 61 59 62 64 63
Professional reinsurers 27 25 27 26 28
Authorized reinsurers 5 5 6 6 6
Captive insurers 60 62 63 62 60
Insurance brokers 62 65 66 63 64
Bank representative offices 43 45 36 30 34
International money brokers 10 10 10 10 10
Licensed financial advisers 67 69 73 71 67
Capital markets services licensees 183 215 221 224 251
Dealing in securities 77 93 90 99 98
Trading in future contracts 40 46 50 48 47
Advising on corporate finance  36 37 37 34 33
Fund management 97 110 113 107 118
Leveraged foreign exchange trading 14 18 19 19 19
Table IV.2 (cont'd) 
                                                      
9 The aim of MAS risk-based supervision is to foster the safety and soundness of financial institutions 
and promote transparency and fair-dealing by institutions in  relation to their customers and counterparties.  It is 
inter-related with the other oversight functions that MAS performs to achieve its supervisory objectives such as: 
authorizing financial institutions to offer financial serv ices, setting regulatory rules and standards, and taking 
actions against institutions and individuals for regulato ry breaches.  The MAS also undertakes surveillance of 
the financial system to identify emerging trends and potential vulnerabilities in order to guide and support its 
regulatory activities (WTO, 2008). 
10 The dispute resolution process comprises a mediati on stage followed by an ad judication stage, where 
necessary.  The consumer may reject the adjudicator's decision, and pursue other resolution options, such as 
filing a lawsuit.  However, the financial institution is bound by the adjudicator's decision should the consumer 
choose to accept it. WT/TPR/S/267/Rev.1 Trade Policy Review 
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   2007 2008 2009 2010 2011 
Securities financing 15 16 16 17 18
Providing custodial services fo r securities 34 38 40 39 40
Real estate investment trust managementc - - 1 7 22
Licensed trust companiesd  31 35 38 40 48
a Prior to 2012, all locally incorporated banks were full banks. As  from 2012, locally incorporated banks comprise 6 full banks  and 
1 wholesale bank. 
b Previously known as restricted banks. 
c Regulation of real estate investment trust ma nagement entered into effect on 1 August 2008. 
d Trust companies are regulated by the MAS since 1 February  2006 when the Trust Companie s Act entered into effect. 
Source: MAS (2011), Annual Report 2010/2011,  Yearbook of Statistics Singapore 2011 ;  and information provided by the 
authorities. 
10. Despite the global economic crisis, Singapore's fi nance and insurance subsector grew by an 
average of 7.1% per year during 2007-11, led by strong growth of Asian corporate activity and increasing wealth accumulation in the region.  Sing apore's resilience as an international financial 
centre is largely attributed to its high regulator y standards, stable economy, pro-business operating 
environment, and its competent financial sector work force.  Moreover, Phase 1 of the development of 
the Marina Bay Financial Centre was complete d in 2010 to support the long-term growth of 
Singapore's financial industry.
11 
11. The MAS offers various incentives to financial institutions (Table IV.3).  The main tax 
incentive is the Financial Sector Incentive (FSI), wh ich offers concessionary tax rates of 12% or 10% 
or 5% on income from qualifying activities that are im portant to Singapore's financial sector growth.  
Financial institutions (both fore ign and national) may obtain these incentives if they meet the 
qualifying criteria.  The MAS monitors the effe ctiveness of all incentives through a series of post-
implementation reviews, which are neith er published nor publicly available. 
12. Singapore has evolved into a major asset-managem ent centre over the past few years, with 
assets reaching S$1.4 trillion in 2010 (up from S$891 billion at end 2006), 80% was from 
international sources.  The Government and th e MAS are encouraging the development of a 
fund-management industry to attract well-recognize d firms to Singapore.  Fund managers approved 
under the FSI-Fund Management award are accorded a concessionary corporate tax rate of 10% on 
income from fees and commissions derived from qua lifying funds managed, investment advisory 
services provided or loans of securities arranged by such managers in Singapore.12 
13. With foreign exchange turnover of US$266 bi llion in April 2010 (US$242 billion in April 
2007), Singapore has the second foreign exchange cent re in Asia-Pacific after Japan, and the fourth 
largest worldwide (up from fifth in 2007).  Singapore's Real Estate Investment Trust (REIT) market is 
also the largest in the Asia-Pacific region after Japan;  22 REITs are listed on the Singapore Exchange 
(SGX) with a combined market capitalization of S$36 billion.13 
 
                                                      
11 This is part of an initiative to extend the business district and double the size of the financial district. 
12 Specific requirements for obtaining AFM status include that the activities pursued should be 
important to Singapore's financial-sector development objectives.  The AFM scheme merged into the FSIF, 
which entered into effect in January 2004. 
13 MAS (2011). Singapore WT/TPR/S/267/Rev.1 
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  Table IV.3 
Incentives schemes offered by the Mo netary Authority of Singapore, 2012  
Scheme and summary descriptio n Changes over review period 
Asset Securitization 
Tax exemption for income derived fro m asset securitization arrangements 
through Approved Special Purpose Vehicles (ASPVs) based in Singapore.  
Tax concessions for withholding tax, stamp duty, and GST concession for 
qualifying transactions Renewed in the 2008 Budget until 2013. 
 
Fund Management Incentive Scheme 
Qualifying funds benefit from a tax exemption on specified income from 
designated investments, subject to  investor residency conditions The 2009 Budget introduced an enhanced tier that does 
not impose any investor residency conditions, subject to the fund meeting certain economic commitments.  The 
scheme is open to fund vehicles in the form of 
companies, trusts, and limited partnerships.  All fund management schemes expire 31 March 2014. 
Locally Administered Trust (i.e. Domestic Trust) 
Tax exemption for specified income (b y qualifying local trusts and eligible 
underlying holding companies that are administered by a trustee company in 
Singapore) that would not have been taxable if received directly by any 
individual None 
 
Tax incentive for trustee company 
Tax concession on qualifying fee inco me derived by an approved trustee 
company from providing trustee services to certain trusts (i.e. trusts under a foreign trust scheme) As a result of the 2011 Budget, a sunset clause of 
31 March 2016 was imposed on the scheme and an 
incentive tenure of 10 years was introduced to the 
recipients of this scheme.  The scope of qualifying 
activities was also expanded. 
Foreign Trust 
Tax exemption on specified income from  designated investments received by 
the foreign trust None 
Foreign Charitable Purpose Trusts 
Tax exemption on specified income fr om designated investments made by 
qualifying charitable-purpose trusts or their eligible holding companies None 
Financial Sector Incentive Scheme (FSI) 
A) Tax concessions on income derive d from FSI-Standard Tier and FSI-
Enhanced Tier qualifying activities in th e debt capital market, equity capital 
market, treasury, fund management, and headquarter services, etc. 
  
 Renewed in the 2008 Budget for 2009-13, and 
enhanced to give 5% conce ssionary tax rate for five 
years on income from Sharia compliant activities.  As a 
result of the 2010 Budget, the list of incentivized 
activities was updated.  Over the review period various schemes were subsumed unde r the FSI scheme:  the 
Commodities Derivatives Traders (CDT) scheme; the 
Futures Members of the Singapore Exchange (SGX).   
Financial Sector Incentive Headquarter Services (FSI-HQ) Scheme 
10% concessionary tax rate on qualif ying income derived from providing 
qualifying services to qualifying network companies Enhanced in the 2009 Budget to, inter alia , grant 
withholding tax exemption (on an application basis) on 
interest payments on qualifying loans taken by a FSI-HQ company. 
Offshore Insurance Business Incentive 
10% tax (for up to 10 years) on qualifying income derived from an offshore 
insurance business conducted in Singapore 
 
 Enhanced in the 2008 Budget to provide 5% 
concessionary tax rate (for five years) on income from offshore Islamic insurance.  Approval period 2008-13. 
As a result of 2010 Budget, the scheme (excluding the 
offshore Islamic concession)  was extended until 2015.  
Tax incentive for Captive Insurers a nd Tax Incentive for Marine Hull 
and Liability Insurers 
Tax exemption on qualifying income derived by approved captive 
insurers/insurers from marine hull and liability insurance business, for up to 
10 years As a result of the 2011 Budg et, the tax incentive for 
captive insurers was extended until 31 March 2018, 
while a sunset clause of 31 March 2016 was introduce for the tax incentive for marine hull and liability 
insurers.  For both incen tives, an award renewal 
framework was introduced for incentive recipients with 
effect from February 2011. 
Table IV.3 (cont'd) WT/TPR/S/267/Rev.1 Trade Policy Review 
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  Scheme and summary descriptio n Changes over review period 
Tax incentive for Specialised Insurers 
Tax exemption on qualifying income derived by approved insurers from a 
qualifying offshore specialized insurance business for five years As a result of the 2011 Budget, the scheme was 
extended until 31 August 2016.   An award renewal 
framework was introduced for incentive recipients. 
Bond Market Incentives 
Tax exemption on income from (a) qualifying debt securities (QDS) and 
(b) trading in Singapore Government  Securities by primary dealers As a result of the 2008 Budget, the scheme was 
extended until 2013.  The sche me was also enhanced to 
exempt all investors from income tax on qualifying income derived from Islamic bonds and debt securities 
of at least ten years. 
Withholding Tax Exemption Regime for Banks 
Banks may benefit from withholding ta x exemption on interest and other 
qualifying payments made to their branch es or other banks outside Singapore Liberalized as a result of the 2011 Budget.  A 
withholding tax exemption is  granted on interest and 
other qualifying payments made by banks and finance 
companies to all non-resident persons.  A sunset clause of 31 March 2021 was also imposed on the scheme. 
Incentive Schemes for Project Finance 
Package of tax incentives for promoting pr oject finance targeted at investors, 
intermediaries, and financing vehicles As a result of the 2011 Budget, these schemes 
(excluding FSI-PF) were extended until 2017. 
 
Source:  Information provided by the authorities of Singapore. 
14. Changes introduced in financial services since Singapore's last Review include:  reducing the 
loan-to-value limit (LTV) for residential propert y loans from 80% to 60% for borrowers who have 
one or more outstanding housing loans, with the ai m of maintaining a stable and sustainable property 
market14;  launching a Code of Conduct for the Private Banking Industry in April 2010 to enhance the 
competency of private banking professionals and foster high market standards15;  and issuing revised 
regulations and guidelines in December 2010, to st rengthen corporate governance standards.  In 
addition, an Enhancing Regulatory Regime for F und Management Companies is expected to take 
effect in early 2012.16 
15. Under the Roadmap for Monetary and Financial Integration of ASEAN, member states have 
committed to progressively liberalizing financial services and capital accounts, and to develop and 
integrate capital markets by 2015.  They have also committed to strengthening the monitoring of capital flows in view of the recent surges of direct and portfolio investments in the region.  Towards 
the integration of capital markets, Malaysia, Si ngapore and Thailand adopted the "ASEAN and Plus 
standards" in 2010;  this will facilitate cross-borde r offerings of securities among these countries.  In 
the bond markets, plans are under way to formulate a set of "development bond indicators" to further 
deepen regional bond markets in the region.
17 
(b) Banking 
16. The Banking Act governs the licensing and operation of commercial banks (local and foreign) 
in Singapore. Commercial banks in Singapore ma y undertake universal banking, which besides 
deposit taking, cheque services and lending, includes any other business regulated or authorized by 
the MAS, including financial advisory services, insurance broking, and capital market services.  
                                                      
14 The minimum cash payment was also increased from 5% to 10% for this group of borrowers.  The 
LTV for borrowers who are not individuals was further lowered to 50%.  The LTV applies to loans by financial 
institutions in Singapore for the purchase of residential property in Singapore. 
15 Under the Code, private banking professionals  are expected to pass a common competency 
assessment called the "Client Advisor Co mpetency Standards" (CACS) to en sure that they have foundational 
level of competency before th ey can engage with clients. 
16 Some of the key changes include the need for an independent fund valuation, and the independent 
"custodization" of customers' monies and assets. 
17 ASEAN online information.  Viewed  at: www.aseansec.org/24538.htm. Singapore WT/TPR/S/267/Rev.1 
 Page 61 
 
 
  Commercial banks ope rate as full banks18, wholesale banks19, or offshore banks.20  The Government 
intends to upgrade all offshore banks to wholesal e banking status over time.  Singapore maintains 
legal distinctions between foreign currency tran sactions conducted in the Asian dollar market and 
Singapore dollar transactions. 
17. By end-2011,  eight foreign banks operating in Singa pore had been awarded qualifying full 
bank (QFB) privileges under their full service licences.21  Full banks are granted the widest range of 
permissible banking activities, while wholesale a nd offshore banks cannot carry out Singapore dollar 
domestic retail operations.  Offshor e banks cannot offer interest-bearing accounts to residents who are 
not existing customers and may extend them credit facilities only up to S$500 million.   Except in 
retail banking, Singapore laws do not distinguish ope rationally between foreign and domestic banks.   
18. Financial institutions may also operate as fina nce companies or merchant banks, as approved 
under the Monetary Authority of Singapore Act.22  Finance companies, licensed under and governed 
by the Finance Companies Act, focus on providing small-scale financing (e.g. instalment credit for 
motor vehicles and consumer durables, and mortga ge loans for housing) but may not offer current 
deposit accounts.  Merchant banks are approved under the Monetary Authority of Singapore Act, are 
governed by the Merchant Bank Notic es, Directives, Guidelines, and Ci rculators, and operate subject 
to the Banking Act.  Typical activities of merchant  banks include corporate finance, underwriting of 
share and bond issues, mergers and acquisitions, portfolio investment management, management 
consultancy, and other fee-based activities.  
19. There are no formal ceilings of foreign owners hip of local banks and finance companies. 
Nonetheless, the Government of Singapore has indicate d that it will not allow a foreign takeover of its 
three major local financial institutions.23 
20. Singapore's banking sector remains strong desp ite the global financial crisis.  As of 
September 2011, commercial banks accounted for a bout 80% of total financial-sector assets.  The 
aggregate of local banks' total capital adequacy ratio (CAR) has remained above the regulatory 
minimum requirement of 10%, averaging 16.1% during 2007-11.  The aggregate non-performing loan 
(NPL) ratio increased from 1.5% in 2007 to 2.4% in 2009 mainly due to the global financial crisis but 
decreased thereafter, and is estimated  at 1.2% for 2011 (Table IV.4). 
                                                      
18 Full banks may provide the whole range of banking business approved under the Banking Act. 
19 Wholesale banks may engage in the same range of banking business as full banks, except they may 
not operate savings accounts denominated in Singapore do llars or accept Singapore dollar fixed deposits of less 
than S$250,000.  Currently, all wholesale banks in Singap ore operate as branches of foreign banks.  Wholesale 
banks may operate in only one location unless the MAS approves an additional location. 
20 Offshore banks may engage in the same activities as full and wholesale banks for businesses 
transacted through their Asian currency units (ACUs), wh ich the banks use to book all their foreign currency 
transactions conducted in the Asian Dollar Market (ADM).   The scope of business transacted in offshore banks' 
domestic banking units (DBU) has slightly more restri ctions on dealings with residents compared with 
wholesale banks. 
21 According to the authorities, a QFB may, with prio r approval of the MAS, enter into an arrangement 
with a local bank for access to its ATM network for the purpose of permitting a QFB cardholder to obtain cash 
advances from their credit or charge card account. 
22 The approval is equivalent to a licence. 
23 USTR (2011). WT/TPR/S/267/Rev.1 Trade Policy Review 
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  Table IV.4 
Main performance indicato rs in banking, 2007-11 
 2007 2008 2009 2010 2011 
Assets 582,859 668,298 706,814 781,607 858,695 
Total non-bank loans (S$ million)a 233,394 272,175 281,297 322,744 420,437 
US$ equivalent (million) 161,9 44 189,116 200,440 250,675 323,239 
Loans by sector (% of total DBU loans)a  
Manufacturing 2.8 2.8 2.5 2.2 3.2 
Building and construction  10.1 12.0 11.6 10.9 11.3 
Housing  19.8 19.1 21.6 22.9 22.7 
Professional and private indi viduals 9.5 9.1 9.3 8.6 8.9 
Non-bank financial instituti ons  8.5 8.0 7.7 7.7 9.2 
Total non-bank deposits (S$ million)a 314,986 347,507 391,495 433,758 483,323 
US$ equivalent (million) 218,5 58 241,459 278,962 336,899 371,587 
Return on assets (%)b 1.3 1.0 1.1 1.2 1.1 
Capital to risk-weighted assets ratio (%)b 13.5 14.7 17.3 18.6 16.2 
NPL ratio (%)b 1.5 1.7 2.4 1.6 1.2 
a Figures for assets, loans and deposits ar e for domestic banking units (DBUs) only. 
b Figures are for local banks' global operations. 
Source:  MAS (2011), Financial Stability Review, November 2011 , Singapore; and information pr ovided by the authorities. 
21. The legal requirements for establishment of a bank in Singapore were, in the main, not 
changed during the review period.24  Domestic banks, which are all locally incorporated, must meet a 
minimum paid-up capital requirement of S$1.5 bill ion and meet risk-based capital requirements based 
on the capital framework established by the Basel  Committee on Banking Supervision (BCBS).  For 
foreign banks to apply for a licence to operate in Singapore, the head office must have minimum 
capital of S$200 million and they must satisfy the capital adequacy requirements under the Basel 
capital framework.  
22. The Banking Act and its accompanying regulations prescribe the minimum capital and 
liquidity requirements as well as prudential limits on credit and investments.  In light of recent developments in the internationa l financial system, the MAS is taking steps to strengthen the risk-
based capital requirements for Singapore-incorporated  banks and promote a mo re resilient banking 
sector.  On 28 June 2011, the MAS announced that Singapore-incorporated ba nks will be required to 
meet CARs that are higher than the Basel III global capital standards.
25 
(i) Singapore-incorporated banks must meet the Basel III minimum CAR requirements 
of 4.5% Common Equity Tier 1 (CET1) CAR and 6% Tier 1 CAR from 
1 January 2013, two years ahead of the BCBS 2015 timeline.  The MAS's existing 
requirement for total CAR will remain unchanged at 10%. 
                                                      
24 The evaluation of new licences is based on, inter alia , the applicant's track record, international 
standing, its reputation, and financial soundness and that of its parent institution or major shareholders;  the 
home-country's supervisory strength and the willingnes s and ability of the home supervisory authority to 
cooperate with the MAS;  whether the applicant has a well-developed strategy in banking or financial services, 
supported by business plans;  and whether the applic ant has risk-management syst ems and processes in place, 
commensurate with the size and complexity of the busin ess.  Refusal by the MAS to grant a licence may be 
appealed to the Minister. 
25 Basel III is a global regulatory standard on bank cap ital adequacy, stress testing, and market liquidity 
risk, agreed upon by the BCBS in 2010-11. Singapore WT/TPR/S/267/Rev.1 
 Page 63 
 
 
  (ii) Singapore-incorporated banks must meet a minimum CET1 CAR of 6.5%, Tier 1 
CAR of 8% and total CAR of 10% from 1 January 2015. 
(iii) In line with Basel III, a capital conser vation buffer of 2.5%, to be met with CET1 
capital, will be phased in between 1 January 2016 and 1 January 2019. 
23. Taking both minimum capital requirements a nd the capital conservation buffer into account, 
Singapore-incorporated banks will be  required to meet a CET1 CAR of 9%, which is higher than the 
Basel III requirement of 7%.26  According to MAS, the revised capital requirements will strengthen 
the bank's ability to absorb unexpect ed losses effectively in a crisis and therefore, protect depositors, 
reduce risks to the real economy, and safeguard financial stability. 
(c) Insurance  
24. The insurance sector is regulated  by the Insurance Act (Cap. 142) and subsidiary legislation, 
notices and guidelines.  To carry out insurance business in Singapore, insurers must be registered with 
the MAS.27  They must maintain two forms of solven cy margin:  a surplus of assets over liabilities 
applies to both the company concerned and its indivi dual funds.  In registering an insurer to write 
either life or general insurance business, the MAS will specify the registration as being for direct 
insurance, reinsurance,  or captive insurance.28  Insurers registered to write both life and general 
insurance are known as composite insurers.  A direct insurer may undertake both direct and 
reinsurance business;  however, a re-insurer is c onfined to only reinsurance business.  Insurers in 
Singapore are subject to prudential and market-conduct standards.   
25. The authorities note that there is no difference in  the standards applied to domestic or foreign-
owned companies, whether they are locally inco rporated or branches of foreign incorporated 
companies.  There is no difference in the requi rements for domestic or foreign-owned companies 
except that offshore insurance bus iness or reinsurance branches ar e exempted from the need to 
maintain risk charges.  
26. Under the Insurance Act, no person is allowed to  obtain effective control (defined as owning 
20% or more of issued shares or voting power) or acquire a substantial shareholding (5% or more of 
issued shares or voting power) of any locally inco rporated insurer without the MAS approval.  The 
Act also requires insurers to seek the MAS approval for the appointment of principal officers of all insurers and the directors of locally incorpor ated insurers (captive insurers are exempt). 
27. The insurance industry accounted for about 6% of  total financial assets or S$152.4 billion as 
of March 2011.  American International Assuranc e (US), Great Eastern Life, NTUC Income and 
Prudential Assurance Singapore (UK) together acc ount for about 87% of life insurance assets.  
Selected indicators of the insurance industry during 2007-11 are shown in Table IV.5.   
 
                                                      
26 MAS (2011). 
27 The Insurance Department in MAS licences insurance companies.   
28 A captive insurer is an insurer whose registration is  restricted to carrying on business which consists 
principally of risks (direct and reinsu rance) of its related corporations. WT/TPR/S/267/Rev.1 Trade Policy Review 
Page 64 
  
  Table IV.5 
Selected indicators of the insurance industry, 2007-10 
(S$ millions) 
Life insurance data 2007 2008 2009 2010 
Total new businessa     
Number of policies 1,047,059 1,094,560 1,058,507 1,065,126 
Sum insured 72,775.7 92,268.1 82,707.7 91,343 
Annual premiums 971.2 1,194.3 1,151.8 1,449 
Total business in forcea     
Number of policies 9,926,661 10,427,504 11,386,229 11,764,901 
Sum insured 491,389.2 534,944.4 586,346.2 629,500 
Annual premiums 7,167.7 7,735.7 8,407.5 9,214 
New annuity business     
Number of policies 6,496 6,317 2,528 2,186 
Considerations 399.5 551 187 152 
Annuity business in force     
Number of policies 65,613 70,755 71,632 72,286 
Annual paymentsb 381.9 546.2 610.4 588 
Net premiums 16,074.3 15,537.2 13,357.6 14,300 
Benefit payments 11,864.1 9,590.2 9,707.8 10,082 
Total assetsc 105,384.0 91,999.1 108,692.8 118,013 
Surrender rate 2.2 2.6 2.3 2.3 
Average 2-year persistenc y rate 92.5 93.0 93.2 n.a. 
Net Premiums     
Direct insurers 122.8 356.1 1,341.0 1,535 
Professional reinsurers  461.0 542.6 1,230.9 2,103 
Gross premiumsd 2,621.9 2,962.5 2,940.8 3,230.6 
Net premiums 2,065.9 2,324.8 2,235.8 2,518.1 
Retention ratio (%) 78.8 78.5 76.0 77.9 
Incurred loss ratios (%) 54.2 58.0 56.0 55.1 
Underwriting results 234.8 151.8 260.9 276.3 
Total assets 7,179.9 7,424.9 7,761.4 8,363.9 
Gross premiums 3,483.5 3,866.8 4,495.4 5,349.4 
Net premiums 2,554.2 2,906.8 3,054.3 3,670.8 
Retention ratio (%) 73.3 75.2 67.9 68.6 
Incurred loss ratios (%) 54.6 55.2 62.8 64.4 
Underwriting results 283.8 94.7 165.6 19.0 
Total assets  8,576.6 9,189.8 10,108.9 11,197.0 
n.a. Not applicable. 
a Total business excludes annuities. 
b "Annual Payments" under annuity business in force, include defe rred annuity payments, whereas benefit payments for annuity 
 relate to the amount of annu ities actually paid during the year. 
c Includes direct insurers and reinsurers. 
d For direct insurers only. 
Source:  MAS (2011), Annual Report 2010/2011 , Singapore. 
28. The MAS takes into account a number of factor s when awarding a direct insurance licence 
including reputation and track record.  According to the authorities, MAS policy on admission to the 
reinsurance market is unchanged.  The mini mum capital requirements of S$10 million and 
S$25 million for direct insurers and re-insurers, resp ectively, have not changed.  Domestic-owned and 
foreign-owned insurers have the same requirements;   for Singapore branches of foreign incorporated Singapore WT/TPR/S/267/Rev.1 
 Page 65 
 
 
  insurers, the paid-up capital of the legal entity is us ed in the assessment of whether the requirement is 
fulfilled.  There is no difference between domest ic or foreign-owned companies as regards the 
personal tax treatment of contributions  to life insurance/pension plans.  
29. The Deposit Insurance and Policy Owner's Protec tion Schemes Act (DI-PPF Act) entered into 
effect on May 2011.  It aims to enhance prot ection schemes for depositors and insurance policy 
owners, and brings them together into a single piece of legislation.29  For the DI scheme, the key 
changes were to increase the coverage limit from S$20,000 to S$50,000 and to expand the scope of 
coverage from insuring individuals and charities to include other non-bank depositors (e.g. sole 
proprietorships, partnerships, compan ies, and unincorporated entities). 
30. The scope of the PPF scheme was extended to c over all accident and health policies written 
by life insurers, and Singapore policies of specifi ed personal lines written by general insurers.  The 
PPF scheme has been enhanced to cover 100% (up from  90%) of the liabilities of life policies, subject 
to caps.  Protected general insurance policies will be fully covered with no caps.  In addition, the 
revised PPF Scheme will be pre-funded, like the DI Sc heme.  Life insurers a nd general insurers will 
pay levies annually into the PPF Life Fund and PPF General Fund, respectively. 
31. A review of Singapore’s existing Insurance Act, regulations and guidelines is being 
undertaken to ensure that Singapore keeps pace with  international standards,  including on group-wide 
supervision, enterprise risk-management, good co rporate governance, and risk-based capital regime.  
(iii) Telecommunications and postal services 
32. Singapore's telecommunications sector has continue d to grow over the last few years, notably 
the mobile market where penetration rose from 129% in 2007 to 150% in 2011 (Table IV.6).  In 2011, 
the 85% of households was internet access (up from 74% in 2007);  access to broadband also 
increased to 85% (71% in 2007);  86% of house holds in Singapore have access to at least one 
computer at home; and there are 5.7 million 3G subscribers (1.7 million in 2007).  The World Economic Forum ranked Singapore second in terms of the impact of IT on the development process 
and competitiveness of nations.
30  According to the latest Interna tional Telecommunications Union, in 
the Information and Communication Technolog y Development Index, Singapore ranked 19th out of 
152 countries.31 
33. Singapore has three main fixed-line services providers (compared with two in 2007)32:  
Singapore Telecommunications Limited or SingTel33, Starhub34, and OpenNet35;  and three main 
mobile telephony providers (the same as in 2007):  SingTel and Starhub through their mobile 
subsidiaries36, and MobileOne (M1).37  As of December 2011, SingTel had 84% market share of the 
                                                      
29 The Deposit Insurance Act, which established the Deposit Insurance (DI) Scheme, as well as 
provisions under the Insurance Act relating to the Po licy Owners’ Protection (PPF) Scheme were repealed. 
30 World Economic Forum online information.  Viewed at:  www.weforum.org/issues/global-
information-technology;  and World Economic Forum (2011). 
31 ITU (2010). 
32 In addition to the main fixed-line operators, there are over 40 providers of IP telephony services.   
33 SingTel held the monopoly on fixed and international telecom services until April 2000.  It is owned 
by Temasek Holdings (54.4%) and public investors. 
34 The main shareholders of StarHub are:  ST Telemedia (owned by Singapore Technologies, in turn 
owned by Temasek);  NTT Communications;  and Qatar Telecom. 
35 OpenNet is a joint-venture between four partners:  Axia NetMedia (Axia), SingTel, Singapore Press 
Holdings (SPH), and Singapore Power Telecommunications (SPT). 
36 SingTel Mobile Singapore Pte Ltd and Starhub Mobile Pte Ltd. WT/TPR/S/267/Rev.1 Trade Policy Review 
Page 66 
  
  fixed-line market and 46% of the mobile phone market.38   There are over 100 Internet services 
providers and 400 licensed Voice services providers.39  
Table IV.6 
Selected teleco mmunication indicators, 2007-11 
  2007 2008 2009 2010 2011 
Fixed telephone subscriptions (million)  1.87 1.88 1. 93 2.00 2.02 
Fixed telephone subscriptions per 100 inha bitants 40.61 39.31 39.04 39.24 38.91 
Mobile cellular subscriptions (million) 5.9 6. 4 6.9 7.4 7.8 
Mobile cellular subscriptions per 100 i nhabitants 129.21 134.42 139.21 145.18 149.61 
Household access to internet  (%) 74 76 81 82 85 
Fixed internet subscriptions (milli on) 1.93 1.12 1. 25 1.33 1.38 
Fixed internet subscriptions per 100 inha bitants 42.04 23.51 25.22 26.22 26.65 
Household access to broadba nd 71 75 80 82 85 
Fixed broadband subscriptions (milli on) 0.9 1.02 1. 17 1.27 1.32 
Fixed broadband subscriptions per 100 inha bitants 19.55 21.45 23.67 24.94 25.53 
Total telecom revenue (S$ billion)  51.68 58.10 62. 74 70.39 .. 
Domestic market (%) 64.9 60.7 64.5 66.2 .. 
Export market (%) 35.1 39.3 35.5 33.8 .. 
.. Not available. 
Source: ITU online information, "ICT Statisti cs Database".  Viewed at:  http://www.itu.int/I TU-D/ict/statis tics/; and 
information provided by the authorities. 
 
34. Overall, Singapore ranked 6th out of 165 countries in the ITU's Information and 
Communication Technology (ICT) Price Basket (2010).  This study found that, measured as a percentage of GNI per capita, the price basket c ontaining fixed-line, mobile cellular, and broadband 
prices is relatively low in Singapore.
40 
35. There have been no major changes to the la ws/regulations and institutional framework 
governing Singapore's telecommunications since its previous Review.  The Infocomm Development 
Authority (IDA), a statutory board under the Minist ry of Information, Communications and the Arts 
(MICA), is Singapore's regulator for all telecommun ication services.  The IDA grants two types of 
licence:  for facilities-based operations (FBO ) and for services-based operations (SBO).41  Any 
foreign or domestic company may provide FBOs (fixe d-line or mobile) or SBOs (local, international 
and internet) telecommunication services in Singapore.   There is no foreign equity restriction and 
there are no limits on the number of licences that ma y be granted, except for reasons of technical 
constraints, such as spectrum ava ilability.  At the end of 2011, 1,055 telecoms licences had been 
                                                                                                                                                                     
37 The main shareholder of M1 are:  Keppel Te lecoms (19.89%);  SPH Mu ltimedia (13.79%);  and 
Aixiata Investment (29.41%). 
38 SingTel online information.  Viewed at:  info.singtel.com. 
39 Voice services excludes mobile and IP telephony services, but includes all other voice-related 
services, e.g. call-back services, intern ational simple resale services, intern et-based voice and data services, and 
international calling card services. 
40 The ICT Price Basket measures the affordability of  fixed and mobile telephony and fixed broadband 
internet services.  Increased market liberalization and competition tends to reduce prices, which in turn leads to 
higher levels of ICT uptake (ITU, 2011). 
41 FBOs are operators intending to deploy any form of telecommunication network, systems and 
facilities to offer telecommunication switching and/or telecommunication services to other licensed telecom 
operators, business, and/or consumers. SBOs are operators intending to lease telecommunication network 
elements such as transmission capacity, switching serv ices, ducts and fibre from any FBO licensed by IDA to 
provide telecommunication services to third parties or resell the telecommunica tion services of FBO. Singapore WT/TPR/S/267/Rev.1 
 Page 67 
 
 
  awarded by the IDA, of which 50 were for FBOs (43 in 2008) and 1,005 for SBOs (879 in 2008).  In 
November 2011, the IDA revised the annual licence fees with effect as from 2013: all FBOs will 
benefit from a reduction of between 20-75%, while mo st SBOs will benefit from a reduction of 20%. 
36. Singapore's Competition Act does not apply, inter alia , to telecommunications and postal 
services, because IDA has its own Telecom Competition Code42 and Postal Competition Code43 
(Chapter III(3)(ii)).  For example, under the Tel ecom Competition Code, recognizing that dominant 
licensees may not have sufficient incentive to enter voluntarily into interconnection agreements, the 
dominant licensee is obliged to offer competing licen sees three options for interconnection:  an IDA-
approved reference interconnection offer;  any existing interconnection agreement between the 
dominant supplier and any other licensee;  and an i ndividualized agreement between the dominant and 
requesting licensee.  To facilitate access by cons umers and allow them to shift from one service 
provider to another, all licensees are obliged to ensure interconnection, interoperability, and access 
with other telecommunications operators.  
37. The IDA determines the cost-based rates for inte rconnection charges for a comprehensive list 
of interconnection services that the dominant licensee,  SingTel, must offer to other licensees.  The 
IDA ensures that prices of interconnection services offered under the reference interconnection offers 
by dominant service suppliers are made public. This  is to enhance transparency and helps potential 
market entrants to undertake price comparison a nd make informed business decisions. Comprehensive 
service level guarantees for ordering, provisioning, a nd fault restoration of interconnection services, 
which are also included in the reference interconn ection offers, provide telecom operators greater 
certainty in obtaining interconnection services and access to dominant suppliers’ networks.  Dominant 
operators are subject to tariff-filing requirements an d need the IDA's approval to offer, modify, or 
withdraw services.  This is to ensure that dominan t operators provide services on just, reasonable, and 
non-discriminatory terms.44   
38. In 2005, the IDA launched its ten-year master  plan Intelligent Nation "iN2015 Vision" with 
the aim of enhancing the competitiveness of the economy as a whole.  Some of the key goals are:  to 
be the best in the world in harnessing telecommunica tions to add value to the economy;  a two-fold 
increase in the value-added of the telecom industry to  S$26 billion;  a three -fold increase in telecom 
export revenue, to S$60 billion;  to create 80,000 a dditional jobs;  to achieve 90% broadband usage in 
all homes;  and to achieve 100% computer ownership in homes with school-going children.45 
                                                      
42 In September 2000, the IDA established the Code of Practice for Competition in the Provision of 
Telecommunication Service (Telecom Competition Code) to help foster competition in the market.  It covers 
ex ante  regulations (e.g. price regulation, inte rconnection, mergers and acquisition) and ex post  regulations (e.g. 
completion rules).  Revisions in the Code (every three years) see stronger reliance on  market forces and self-
regulation as more effective means of sustaining competition in the long term.  For example, the IDA will 
encourage non-dominant licens ees to resolve disputes through commerci al negotiations or alternative means of 
dispute resolution. 
43 In May 2008, the IDA established the Postal Competition Code to promote competition in the 
provision of basic letter services.  The Code sets fort h rules to facilitate entry of  new operators and prevent 
abuse by operators not yet subject to  constraints of market forces, and puts in place an enforcement regime 
against actions that threaten competition. 
44 The IDA makes public the prices of interconnection services offered by dominant suppliers under 
their reference interconnection offers in order to help potential market entrants greater certainty in obtaining 
interconnection services and access to  dominant suppliers' networks. 
45 IDA (2010). WT/TPR/S/267/Rev.1 Trade Policy Review 
Page 68 
  
  Main regulatory developments since 2007 
 
39. In June 2009, SingTel was exempted from domin ant licensee obligations for the provision of 
Terrestrial IPLC services and backhaul services.  Si ngTel will no longer be requi red to file tariffs, and 
will have more flexibility in packaging and bundlin g these services.  The exemption was granted for 
both services since the IDA determined that th e two service markets are competitive and that 
SingTel's market share had also fallen over the years.46  The IDA deemed that it was no longer 
necessary to impose ex ante dominant licensee oblig ations on SingTel to preserve fair and effective 
competition among the operators in these two markets.  
40. In December 2010, the IDA issued the revised Telecom Competition Code 2010, which 
entered into force on 21 January 2011.47  These changes aim to safeguard consumers' interest and 
further promote competition.  Key changes to the Code include allowing the IDA to apply a 
prohibition against abuse of dominant position to any licensees found to have significant market power even though they may not yet be classified by the IDA as dominant licensees.  The Code was 
re-issued in 2012 due to amendments made  to the Telecommunications Act (TA). 
41. The amended TA entered into operation on 1 February 2012 to ensure that Singapore's 
legislative framework keeps track  with the rapidly changing telecoms industry whilst encouraging 
competition.  Key changes to the TA include:  incr easing the maximum financial penalty that may be 
imposed on telecommunication licensees (to S$1 million or 10% of annual business turnover for 
licensable services, whichever is higher);  updati ng the consolidation provision to include new 
concepts and business models (such as business trust structure);  and providing powers for the IDA to 
issue written orders to building owne rs and developers to ensure thei r compliance with code practices 
issued for the provision, maintenance, and u se of, and access to, space and facilities for the 
installation and operation of telecommunication systems. 
42. The IDA also completed its second triennial re view of SingTel's Re ference Interconnection 
Offer (RIO) in 2012.
48  The key change made to RIO was the full liberalization of access to SingTel's 
submarine cable landing stations.  Previously, on ly licensees with Indefeasible Rights of Use (IRUs) 
or long-term capacity may access and co-locate at th e landing stations.  With the lifting of such 
restrictions in the latest RIO review, any fac ilities-based licensee may de ploy and access SingTel's 
submarine cable landing stations for the purpose of providing backhaul services to other licensees.  
This is expected to bring further co mpetition to the backhaul services market. 
43. Other measures taken by the IDA to help consumers and improve welfare include:  a 
Premium Rate Services Code, introduced in October 2007, to guide the conduct of  providers that offer 
premium rate services, which are mobile cont ent services (e.g. ringtone, game downloads, quiz 
services, news services, and chat-lines);  the Full Mo bile Number Portability framework, adopted in 
June 2008, to allow end-users to retain full use of their existing phone number even after switching 
mobile operators;  a set of Guidelines on Contract  Length and Early Termination Charges, introduced 
in 2010, to regulate the maximum contract length and early termination charges that  operators can 
impose for mobile, broadband, and fixed-line services,  so as to lower the barrier for consumers to 
terminate services and/or switch operators;  and an increase in the minimum quality of service 
                                                      
46 According to the authorities, SingTel's market shar e in terrestrial IPLC services was about 45% and 
less than 30% in backhaul services in 2007. 
47 The revision takes into account market developments between 2003 and 2005, IDA's experience with 
the implementation of the Code, and feedback from consumers and industry. 
48 RIO refers to the IDA-approved reference interconnection offer by SingTel, subject to the Telecom 
Competition Code requirements. Singapore WT/TPR/S/267/Rev.1 
 Page 69 
 
 
  standards for 3G mobile services, in January 2012.   Other consumer protection measures take have 
taken effect in 2012 include the introduction of a premium-rate-services barring service, a data 
roaming bill cap to reduce expenses by consumers;  and the requirement for broadband operators to 
publish typical download speeds by end users. 
Postal services 
 
44. Singapore's basic letter services market was lib eralized on 1 April 2007 after the exclusivity 
rights granted to Singapore Post Ltd (SingPost) expired.49  Local and foreign operators are allowed in 
both domestic and international mail services.  Th e IDA grants two types of licence:  for postal 
services operators (PSOs) with universal service obligations (e.g. provid ing island-wide letter 
collection and delivery services, maintaining a minimum number of post boxes and post offices for easy consumer access);  and for express letter licensees.  Licences for PSOs are for ten years, subject to an annual fee of 0.4% of annual audited gr oss turnover (minimum of S$4,000).  Licences for 
express letter service operators are valid until cancelle d or suspended and are subject to a one-time 
registration fee of S$200.  At end-2011, five opera tors had been licensed to offer basic mail services, 
of which SingPost is designated as Public Postal Licensee
50;  and there were over 140 express letter 
licensees. 
45. To facilitate market entry and competition, th e IDA introduced the Postal Competition Code 
2008 and Postal Services Operati ons Code 2008.  In addition, Si ngPost is required to develop a 
Reference Access Offer to provide downstream deliv ery services to all requesting licensees;  and to 
adopt a Reference Offer to address common inter-ope rator issues that are likely to arise between 
SingPost and other licensees in Singapore's basic letter services market. 
(iv) Transport 
(a) Maritime transport 
Overview 
 46. The maritime sector remains a pillar of the Singapore economy, cont ributing about 7% of 
GDP and about 5.5% of employment in 2010.  Over  5,000 maritime service companies are established 
in Singapore, including more than 120 international shipping groups.  Singapore remains the busiest 
port in the world in terms of annual vessel arrival tonnage (2.12 billion gross tons as of December 2011) and the world's top bunkering port (43.2 million tons in 2011).  In 2011, the Port of 
Singapore's annual container throughput was 29. 9 million TEUs, ranked second behind Shanghai.  
The Singapore Registry of Ships ranks among the top 10 worldwide. 
47. Faced with intensifying competition among major ports in the region, the Government has 
taken a number of steps to enhance the compe titiveness of Singapore's port.  Measures include 
streamlining the preferential corporate tax regime fo r the maritime sector (Maritime Sector Initiative); 
and further investments in port infrastructure.  The Government's principal maritime policy objectives 
are to promote trade and investment in Singapor e to strengthen its position as a global hub port and 
international maritime centre that offers a one-st op-shop for all port, shipping, and maritime activities.  
                                                      
49 Liberalization in other segments, such as express letter services, was in 1995. 
50 SingPost manages the centralized postal code management system, while providing access to the 
postal codes database to all interested PSOs.  SingPost is the only operator to issue national stamps. WT/TPR/S/267/Rev.1 Trade Policy Review 
Page 70 
  
  48. The main legislation governing Singapore's maritime sector comprises the Maritime and Port 
Authority of Singapore Act, the Merchant Shipping Act, the Carriage of Goods by Sea Act, and the 
Bills of Lading Act, as well as regulations made u nder these Acts.  Singapore is a Member of the 
International Maritime Organizati on and party to a wide range of  international conventions on 
maritime safety and protection of the marine environment.  
GATS commitments 
 
49. Singapore's GATS commitments in the maritime  sector include shipping agency services, 
brokerage services, and freight transportation, except cabotage services.  There are no limitations on 
market access or national treatment with respect to the first three modes of supply.  On the presence of 
natural persons, national treatment is unbound and market access is subject to Singapore's horizontal 
commitments.  Additionally, Singapore has committed to provide non-discriminatory access to port services, excluding berth and berthing services.  Singapore's MFN exemptions under the GATS include reciprocal rights with regard to four  maritime transport subsectors based on bilateral 
agreements.  Singapore has bilateral shipping agre ements with China, Germany, India, Korea, 
Myanmar, and Viet Nam. 
Port services 
 
50. The Maritime and Port  Authority of Singapore (MPA) under the Ministry of Transport 
implements maritime policy, including licensing of maritime and port services and facilities, and 
managing port waters and ensuring na vigational safety.  Port dues and marine services are the MPA's 
main source of income. 
51. Singapore's ports are managed under licence by PSA Corporation Limited (PSAC) and Jurong 
Port Private Limited.
51  PSAC manages four container terminal s (Brani, Keppel, Pasir Panjang 1 & 2, 
and Tanjong Pagar), which handle most  of Singapore's container traffic.  PSAC has four joint ventures 
with foreign shipping lines to operate dedicated berths  in some parts of these terminals.  Expansion of 
the Pasir Panjang Terminal is under way to cater fo r future growth in container volumes, which will 
increase container handling capacity in the Port of Singapore from currently 35 million TEUs to 
around 50 million TEUs.  Jurong Port Private Limi ted operates cargo terminal facilities to handle 
conventional cargo, bulk cargo, and containers.  A ccording to the authorities, berth and berthing 
services are provided by the terminal operators on a non-discriminatory basis.  However, operational 
and commercial considerations ma y be involved in determining how the berths are allocated. 
52. Singapore has liberalized (i.e. issued more than  one licence) for certain port services, such as 
towage and bunkering.  Pilotage ser vice is provided by one licensee, PSA Marine Private Limited, for 
reasons of navigational safety.  Maintenance and repair services are carried out by private companies/shipyards.  Singapore's competition law applies to maritime service providers 
(Chapter III(3)(ii)).  
Maritime services 
 
53. Singapore has no laws or regulations  restricting foreign participa tion in international maritime 
freight and passenger transport.  The Singapore Regi stry of Ships registers ships of citizens and 
permanent residents of Singapore and of companies incorporated in Singapore.  The registry ranks 
among the ten largest in the world, with more than  4,000 registered vessels, equivalent to 57.4 million 
                                                      
51 PSA was corporatized on 1 October 1997 and is fu lly owned by Temasek Holdings.  Jurong Port was 
corporatized on 1 January 2001 and is a fully owned subsidiary of JTC Corporation. Singapore WT/TPR/S/267/Rev.1 
 Page 71 
 
 
  gross tons (as of December 2011).  There are no nationality requirements for the crew on-board a 
Singapore-registered ship, and Singapore r ecognizes competency from reputable maritime 
administrations issued to officers and engineers who serve on-board. 
54. To develop Singapore as a leading international maritime centre, the MPA collaborates with 
industry partners to provide shipping companies wi th a one-stop location for port, shipping, and other 
maritime activities, as well as services in ship manage ment, ship financing, marine insurance, ship 
broking, maritime legal services, and marine and of fshore engineering.  Singapore has consolidated 
all tax incentive schemes for the maritime sector unde r the Maritime Sector Incentive (Table IV.7).  
Table IV.7 
Main features of the Maritime Sector Incentive, 2011  
Name of award Major benefits 
MSI-Singapore Registry of Ships (MSI-SRS) Qualifying income derived from operating or chartering of a Singapore-registered 
ship outside the port limits of Singapore is tax-exempt.   
MSI-Approved International Shipping Enterprise 
(MSI-AIS) 
 Qualifying income derived by an approved company from operating or chartering of 
Singapore- and foreign-flagge d vessels outside the port limits of Singapore is tax 
exempt for up to 10 years, with the possib ility of extension for further periods of 
10 years up to a total of 30 years.  
MSI-Shipping-related Support Services (MSI-SSS)  
 
MSI-Maritime Leasing (MSI-ML) Qualifying incremental  income derived from the provision of shipping -related 
support services by an approved company is eligible for a concessionary tax rate of 
10% for five years. 
An approved ship/container i nvestment vehicle benefits from 0%, 5% or 10% tax on 
qualifying income for 5 years.  The approve d manager benefits from a concessionary 
tax rate of 10% for 5 years.  
Source : Singapore authorities. 
55. The MPA also provides maritime companies with other support schemes, such as the 
S$100 million Maritime Innovation and Technology (MINT) Fund a nd the S$100 million Maritime 
Cluster Fund (MCF), to encourage maritime resear ch and development, as well as manpower and 
business development needs.   
56. Singapore has extended the block exemption for liner shipping agreements under the 
Competition Act until 31 December 2015.  While frei ght rates are deregulated, the block exemption 
permits agreements between liner operators, incl uding on capacity and prices, subject to certain 
conditions for liner agreements with more than 50%  market share.  The block exemption, which is 
administered by the Competition Commission, is aimed at aligning Singapore's competition regime in the maritime sector with that of other major juri sdictions, including the United States, Australia, and 
Japan.  Liner conference agreements have commercia l significance mainly in intra-Asian trade.   
(b) Air transport 
Overview 
 
57. The air transport sector contributed nearly 2%  of GDP and about 0.8% of employment in 
2010.  Changi Airport is one of the major air hubs  in the Asia-Pacific region;  it was the world's 
seventh busiest international airport in 2011, ha ndling 46.5 million passengers (with some 100 airlines 
flying to over 200 cities in over 60 countries) and 1.865 million tons of air cargo.  The Government 
pursues an open skies policy.  Since its last TPR, Singapore has further opened up its air services sector, mainly bilaterally and within the framewo rk of ASEAN to create new business opportunities 
for carriers based in Singapore and abroad.  The Civil Aviation Authority of Singapore (CAAS) has 
been restructured to separate its strategic and regulatory functions from the management of the WT/TPR/S/267/Rev.1 Trade Policy Review 
Page 72 
  
  airport, to allow the new airport company gr eater flexibility in operating in an increasingly 
competitive environment.  The CAAS has launche d a new incentive scheme (Aviation Development 
Fund) to enhance the competitiveness of the Singapore aviation industry. 
GATS commitments  
 
58. Singapore has scheduled an MFN exemption under the GATS for computer reservation 
systems services, whereby market access and nationa l treatment are based on reciprocity in mutual 
concessions, but not necessarily in the same ar eas, as established under bilateral air services 
agreements. 
Air services 
 
59. The conditions and level of market access gran ted in air transport services are primarily 
governed by Singapore's bilateral air services agreements, regional (ASEAN), and plurilateral 
agreements (Multilateral Agreement on the Libera lization of International Air Transportation - 
MALIAT).  Singapore has extended its network of bilateral air services agreements from 90 at the 
time of its last TPR to 113 countries.  Over 40 of  them provide for open skies arrangements.  Open 
skies arrangements typically provide for multiple carriers to operate unlimited 3rd, 4th and 5th freedom 
cargo and passenger services (in terms of both capaciti es and frequencies, using any aircraft type on 
an open route schedule).   
60. During the review period, ASEAN members ag reed to gradually open up their aviation 
markets for unlimited air cargo services and un limited air passenger services to all cities with 
international airports within the region (Table IV.8 ).  These agreements are seen as a significant step 
towards open skies among ASEAN members under the region's objective of an ASEAN Economic Community by 2015.  In November 2010, A SEAN members concluded the ASEAN-China Air 
Transport Agreement.  
Table IV.8 
ASEAN air services agreements signed since 2006 
Agreement Entry into force 
of the Agreement Description 
ASEAN Multilateral Agreement on Air Services (MAAS) 22 December 2009 Designation of carriers based on either substantial ownership and effective 
control (SOEC) or principal place of business and effective control 
(PPOBEC) is subject to acceptance by the ASEAN members.  Multiple 
designation applies.  Covers unlim ited capacities and exercise of 3
rd, 4th and 
5th freedom traffic rights for air pass enger services among ASEAN capital 
cities. 
ASEAN Multilateral Agreement on the Full Liberalization of Passenger Air Services (MAFLPAS) 1 July 2011 Builds on the MAAS to allow designated carriers of ASEAN members to 
provide air passenger services from intern ational airports in one territory to 
cities with international airports in  another territory within the ASEAN 
region, with full 3
rd, 4th and 5th freedom traffic rights. 
ASEAN Multilateral Agreement on 
the Full Liberalization of Air 
Freight Services (MAFLAS) 13 October 2009 Similar to the MAAS and th e MAFLPAS except that the MAFLAFS covers 
the 3rd, 4th and 5th freedom traffic rights for air freight services among 
ASEAN cities with international airports. 
ASEAN-China Air Transport 
Agreement (AC-ATA) 9 August 2011 Allows designated carriers of ASEAN members to provide air services 
from any city with an inte rnational airport in its terr itory to any ci ty with an 
international airport in the territory  of China and vice versa with  3rd and 4th 
freedom traffic rights.  Discussions are ongoing to expand the Agreement to include 5
th freedom traffic rights. 
Source:  Singapore Authorities. Singapore WT/TPR/S/267/Rev.1 
 Page 73 
 
 
  61. Airlines must be designated by their respectiv e governments to provide scheduled air services 
to and from Singapore.  The designation criteria und er the agreements between Singapore and other 
parties are:  (i) principal place of business in Singa pore;  and (ii) substantial ownership.  For both 
criteria, there is a requirement of effective control to be vested in the nationals and/or the designating 
State.  In 2011, eight airlines held an air operato r's certificate issued by the CAAS to provide air 
services on scheduled and non-scheduled routes.  The major Singapore carriers are Singapore Airlines (SIA), Singapore Airlines Cargo, SilkAir, Tiger Airw ays, and Jetstar Asia Airways.  SIA is a publicly 
listed company, majority-owned by the Government through Temasek Holdings (55.59%).  SIA's wholly owned subsidiary, SilkAir, provides regiona l air transport services.  Licensing requirements 
for air transport services remain unchanged.
52  According to the authorities, there is no preferential 
treatment for Singapore airlines. 
Airport management and ground-handling services 
 
62. The aviation industry regulator, the Civil Aviation Authority of Singapore (CAAS), has been 
restructured, by separating its regulatory functions from the operation of Changi Airport and Seletar 
Airport.  The responsibilities of the reconstituted CAAS include economic regulation of the airport 
operator, air services negotiations, regulation of aviation safety, and air navigation services.  
Additionally, it has the task of developing aviatio n-related sectors, including air cargo, aircraft 
maintenance, repair, overhaul, and business aviation.   The main regulatory instruments are the Civil 
Aviation Authority of Singapore Act 2009 and the Air Navigation Act. 
63. In June 2009, Changi Airport Group (Singapore)  Pte Ltd, a 100% state-owned corporation, 
was incorporated and granted a licence in July 2009 to  operate Changi Airport a nd Seletar Airport.  Its 
portfolio includes handling overseas investments and contracts through the company's international 
arm, Changi Airport International.  The airport operator is required to comply with the licence 
conditions, as well as the codes of practice pr omulgated by CAAS.  These codes govern service 
performance standards pertaining to the two airports and fair competition in the airport market.  The 
Airport Competition Code introduced in July 2009 pr ohibits anti-competitive agreements and abuse of 
dominance on the part of Changi Airport Group, as well as mergers and acquisitions that will lessen 
competition in the airport market.  Any operator licensed  to operate an airport is authorized to make 
by-laws after consulting CAAS and with the approval of the Minister for Transport.  The by-laws may provide for the proper management, operation, safety, and security of the airport, securing the safety 
of persons and of aircraft at the airport, regulati ng traffic at the airport, and preserving orderly conduct 
at the airport.  According to th e authorities, slot allocation rul es are in accordance with the IATA 
World Scheduling Guidelines and have not changed since the last TPR. 
64. The CAAS has put in place a pricing regulatory framework, which caps the aeronautical 
revenue per passenger (revenue yield cap) that Chan gi Airport Group may charge at Changi Airport.  
The caps are set after taking into account allowable operating and capital expend iture and a portion of 
profits from non-aeronautical activities.  This appr oach (cross-subsidy) aims to lower the overall 
aeronautical charges on airport users.  The re venue yield cap determination process includes 
mandatory consultation with airport users. 
65. The Government's strategy is to expand airpor t capacity ahead of demand.  The airport can 
handle about 73 million passengers annually, 57% more  than actual passenger traffic in 2011.  To 
address the risk of the corporatized airport operator under-investing or delaying investments in airport 
infrastructure, the CAAS regulates Changi Airport Group in the planning of airport infrastructure, 
                                                      
52 Air Navigation (Licensing of Air Services) Regulations.  CAAS online information.  Viewed at: 
http://www.caas.go v.sg/caas/en/Regulations/Licensing _of_Air_Services/2 .1.3.14.pdf. WT/TPR/S/267/Rev.1 Trade Policy Review 
Page 74 
  
  including setting triggers for planning add itional passenger capacity and timeframes for the 
construction of the necessary infrastructure, runways,  and other facilities.  Changi Airport's land has 
been leased to the airport operator,  while the CAAS retains overall control over land use to ensure it is 
developed to meet the needs of all airport users. 
66. In order to diversify Singapore's air freight handling activities, a number of infrastructure 
projects were completed during the review period, including specialized terminals for perishables 
(Coolport@Changi) and high-value collectibles (Singapore Freeport).  The opening of an Air Cargo Express hub is planned for 2012.  Infrastructure and f acilities are being upgraded at Seletar Airport to 
develop Singapore as an aviation hub and to support the development of the Seletar Aerospace Park 
(SAP).  The SAP will support activities in the mainte nance, repair and overhaul (MRO) of aircraft and 
components, business and general aviation, manufact uring and assembly of aircraft engines and 
components, as well as traini ng and research and development.
53  There are presently over 
100 companies carrying out MRO activities employing over 19,000 workers in Singapore. 
67. Two companies currently provide ground-handl ing services (SATS and Dnata Singapore Pte 
Ltd).54  US-based Aircraft Service Internationa l Group (ASIG) holds the third ground-handling 
contract, awarded by Changi Airport Group in June 2011.  With its ten-year contract, ASIG will be 
able to provide a full range of passenger handling, apron handling, and cargo handling services.  In 
addition, SIA Engineering Company provides "technical ramp" services, such as aircraft marshalling and parking, tow-in/push-back services, and aircraft  exterior cleaning.  The right of self-handling has 
been negotiated under the bilateral air services agreements with Botswana, Australia, and the 
MALIAT. 
68. The Aviation Development Fund (ADF) was launched by the CAAS with a budget of 
S$100 million over a five-year period between  April 2010 and March 2015 (Table IV.9). 
Table IV.9 
Main non-tax incentive schemes in the civil aviation sector  
Name of scheme Main incentives 
Aviation Development Fund - Aviation 
Innovation Programme (AIP) To encourage innovation and development of  new or enhanced capabilities in niches 
of excellence within the aviation industr y.  Open to all Singapore-registered 
companies or organisations with a presen ce in Singapore, including institutes of 
higher learning and research centres.  The supported projects must have an 
innovative element.  Grants of up to 70% of qualifying expenses, capped at 
S$2 million per project over two years, to support the purchase/lease of equipment, 
IPR acquisition, staff salaries, training cost s, and consultancy/professional services. 
Budget of S$25 million. 
Aviation Development Fund - Aviation 
Partnership Programme (APP) To support the adoption of industry-level sta ndards or processes that help to enhance 
overall productivity, effectiveness and compe titiveness.  Initiatives  will be identified 
by the CAAS in consultation and partners hip with the industry.  APP provides two 
tiers of funding support: the first is for the development of common standards and 
platforms; the second is to fund companies for up to 70% of the cost required to 
adopt the established initiative. 
Aviation Development Fund - Aviation 
Manpower Programme (AMP) To support manpower development efforts of the Singapore aviation industry.  Four 
initiatives have been launched under th e AMP, such as the CAAS Aircraft 
Maintenance Examinati on Rebate Programme. 
Source:  Singapore authorities. 
                                                      
53 Some of companies that have decided to set up operations in the SAP include Jet Aviation, Rolls-
Royce, Eurocopter, Bell Helicopter, Cessna, ST Ae rospace, Hawker Pacific and Fokker Services.   
54 SATS is a publicly held corporation traded on the Singapore stock exchange.  Its major shareholder 
is Venezio Investments Pte. Ltd., an indirect wholly-owned subsidiary of Temasek Holdings Pte. Ltd.  Dnata 
Singapore Pte Ltd is a member of the Emirates Group of companies. Singapore WT/TPR/S/267/Rev.1 
 Page 75 
 
 
  (v) Professional services  
(a) Commitments under the GATS and FTAs 
69. Singapore has undertaken specific commitments on professional services under the GATS, 
the ASEAN Framework Agreement on Services (AFAS), and several of its FTAs, negotiated both 
directly or together with ASEAN Members (Table IV.10). 
Table IV.10 
Specific commitments on professional services undertaken in the GATS and FTAs, 2012  
   Singapore- 
New Zealand 
(2001) Singapore-
Australiaa 
(2003) Singapore-
Japan 
(2002) Singapore-
EFTA 
(2003) US-
Singaporea
(2004) Singapore-
Jordan 
(2005)  
GATS AFAS 
Legal services (861)    X X  X  
Accounting, auditing and 
bookkeeping services 
(862) X X X X X X X 
 X 
Taxation services (863) X X X X X X X X 
Architectural services 
(8671) X X X X X X X 
 X 
Engineering services 
(8672) X X X X X X X 
 X 
Integrated engineering 
services (8673)  X  X X X X 
  
Urban planning and 
landscape architectural 
services (8674)  X X X X X X 
 X 
Medical and dental 
services (9312) X  X X X X X 
 X 
Veterinary services (932) X   X X X X X X 
Services provided by 
midwives, nurses, 
physiotherapists and 
para-medical personnel 
(93191)   X X X X X 
 X 
Other     X    
 
 Korea-
Singaporea 
(2006) Panama-
Singaporea 
(2006) Trans-
Pacific SEP 
(2006) ASEAN-
Korea 
(2009) Peru-
Singaporea 
(2009) China-
Singapore 
(2009) ASEAN-
Australia, 
NewZealand 
(2010)  
Legal services (861)        
Accounting, auditing and bookkeeping 
services (862) X 
 X 
 X X X X X 
Taxation services 
(863) X 
 X 
 X X X X X 
Architectural services 
(8671) X 
 X 
 X X X X X 
Engineering services 
(8672) X 
 X 
 X X X X X 
Integrated engineering 
services (8673) X 
 X 
 X  X   
Urban planning and 
landscape architectural 
services (8674) X 
 X 
 X X X X X 
      Table IV.10 (cont'd) 
 WT/TPR/S/267/Rev.1 Trade Policy Review 
Page 76 
  
   Korea-
Singaporea 
(2006) Panama-
Singaporea 
(2006) Trans-
Pacific SEP 
(2006) ASEAN-
Korea 
(2009) Peru-
Singaporea 
(2009) China-
Singapore 
(2009) ASEAN-
Australia, 
NewZealand 
(2010)  
Medical and dental services (9312) X 
 X 
 X X X X X 
Veterinary services 
(932) X 
 X 
 X X X X X 
Services provided by 
midwives, nurses, physiotherapists and 
para-medical 
personnel (93191) X 
 X 
 X  X   
Other        
a Negative list approach used for scheduling of services commitments. 
Note: "X" indicates that either a full or partia l commitment has been made in this subsector. 
Source:   IE Singapore online information.  Vi ewed at:  http://www. fta.gov.sg/sg_fta.asp. 
70. Progress in developing and implementing mutual  recognition arrangements (MRAs) under the 
AFAS has been slow.  Five ASEAN MRAs have been reached on:  medical practitioners (2009);  
dental practitioners (2009);  architectural servi ces (2007);  nursing services (2006); and engineering 
services (2005).  Two ASEAN framework arrangement s on services to facilitate the development of 
MRAs have been reached on:  accountancy servi ces (2009), and surveying qualifications (2007).55  
MRA discussions are most advanced in health-related areas.56  An estimate could not be given of 
when these or other MRAs would be implemented.  
71. Similarly, there are provisions in a number of Singapore's FTAs encouraging the relevant 
bodies within the parties' territories to develo p licensing standards and mutual recognition of 
professional degrees.  The authorities noted that und er FTAs, work is only under way in establishing 
licensing standards and mutual recognition of professional dental degrees.  
(b) Developments over the review period (2008-12) 
72. There has been some opening of domestic lega l services to foreign law practices (FLPs) in 
response to increasing demand for corporate and commercial legal services.  Previously, while Singapore maintained a liberal policy with respect to  the practice of foreign law, the domestic market 
was tightly regulated.  The most significant change  to legislation governing the legal profession has 
been the opening up of "permitted areas" of domest ic law to FLPs licenced under a newly introduced 
Qualifying Foreign Law Practice (QFLP) scheme,  as well as to joint ventures between FLPs and 
Singapore law practices (SLPs) under the existing Join t Law Venture (JLV) scheme (Table IV.11).  
These permitted areas include commercial areas of law but exclude: constitutional and administrative 
law;  conveyancing;  criminal law;  family la w;  succession law (including wills, intestate succession, 
and probate and administration);  trust law (where the settlor is an individual);  litigation;  and 
appearance in any hearing before a quasi-judicial or regulatory body, authority or tribunal in 
Singapore.  The practice of permitted areas of Si ngapore law may be undertaken through a Singapore 
lawyer (SL), or a foreign lawyer (FL) who has obtained a Foreign Practitioner Certificate, which 
involves passing an examination (introduced in 2012). 
                                                      
55 ASEAN online information.  Viewed at:  http://www.aseansec.org/19087.htm. 
56 WTO document WT/TPR/S/261. Singapore WT/TPR/S/267/Rev.1 
 Page 77 
 
 
  73. In addition, Singapore's regime for internationa l commercial arbitration has been opened up;  
rules have been amended giving SLPs greater flexibility to collaborate with FLPs, given the 
increasingly competitive and globalized legal services markets57;  and greater flexibility has been 
introduced to admit Queen's Counsel  for cases where expertise is required or when a Singapore Senior 
Counsel is unavailable.  There have also been some amendments to the Legal Profession Act to 
amend the regime for admission to the Singapore Bar. 
74. Incentives have been introduced to encourage la w practices to do more international services 
work from Singapore.  As a result of the 2010 Budget, the Development and Expansion incentive (DEI) scheme was extended to international legal ser vices.  The incentive is open to law practices that 
are incorporated as companies in Singapore.  La w practices awarded the incentive will enjoy a 10% 
concessionary tax rate for a period not exceeding 5 years on their qualifying income derived from the 
provision of international legal services in Singapore, in excess of a base (Chapter III(3)(i)). 
75. Amendments made to the Accountants (Public  Accountants) Rules pertain to continuing 
professional education (CPE) requirements (to add flex ibility to the annual requirements in line with 
international benchmarks), the recognition of inte rnational experience for the purposes of registration 
(to facilitate registration of experienced audito rs from other jurisdictions), and the Code of 
Professional Conduct and Ethics for Professional Account ants (to update it in line with international 
benchmarks). 
76. In 2011 there were 1,037 foreign lawyers pr acticing in Singapore, and 116 foreign law 
practices, compared with 4,206 Singapore lawy ers and 821 Singapore law practices.  Around one-
quarter of registered architects and engineers in Singapore are foreigners.  Data on foreign 
accountants registered in Singapore was not available. 
77. Key features of Singapore's legal services and accountancy regimes are summarized in 
Table IV.11, together with the respective featur es of Singapore's regimes for architectural and 
engineering regimes, which remained unchanged over the review period. 
Table IV.11 
Selected professional services, key features, 2012 
Legal services 
Legislation Legal Profession Act (LPA) 
Regulatory bodies The Singapore Institute of Legal Education (SILE) oversees the professional training, education and examinati on of 
persons seeking to be admitted as SLs 
The Attorney-General oversees the licensing and regulation of foreign law entities, SLs and FLs working in foreign law 
entities, and FLs working in Singapore Law Practices 
The Law Society of Singapore oversees the regulation of SLs practicing in SLPs.  Membership with the Law Society is 
mandatory for SLs and FLs who hold a FPC 
Professions Advocate and Solicitor of the Singapore Supreme Court (aka SLs) 
Requirements for 
SLs and Singapore 
law practices (SLPs) Individuals (Qualified Persons) seeking admission to the Singapore Bar must be: 
(a) a graduate from the National University of Singapore (NUS) or Singapore Management University (SMU) with at 
least a second lower honours or equivalent;  or 
(b) have obtained a law degree overseas and fulfil various other requirements, including:  (i) being a Singapore citizen/permanent resident;  (ii) obtaining an approved law degree as a full-time internal candidate for at least three years from an approved university (listed in the schedules to the Legal Profession (Qualified Persons) Rules);  and (iii) passing 
Part A of the Singapore Bar Examinations and fulfilling 6 months of relevant legal training 
 All above-mentioned Qualified Persons must attend the Part B course and pass Part B of the Singapore Bar Examinations.  Thereafter, they must also fulfil 6 months of practice training at a SLP 
 
SLs may be organized as a sole proprietorship, partnership,  limited liability partnership (LLP), or law corporation (LC) 
 Table IV.11 (cont'd) 
 
                                                      
57 These relate to increased profit and equity share provisions and provisions allowing concurrent 
partnerships. WT/TPR/S/267/Rev.1 Trade Policy Review 
Page 78 
  
    
Requirements for 
foreign lawyers (FLs) and foreign law practices (FLPs) An FLP is a law practice (including a sole proprietorship, partnership, limited liability partnership (LLP), or law 
corporation (LC)) providing legal services in foreign law in Singapore or elsewhere but does not include an SLP. All FLPs are regulated by the Attorney-General, through a licensing regime under Part IXA of the LPA.  There are different categories of licences accorded to FLPs with different privileges and licence conditions attached: 
(a) FLP:  may offer the full range of foreign-law-related legal services.  It may not practice Singapore Law, except in the 
context of international commercial arbitration; 
(b) Qualifying Foreign Law Practice (QFLP):  may employ their own SLs, or FL's who have obtained a Foreign 
Practitioner Certificate (FPC) to practice Singapore law in "permitted areas" of legal practice (see above).  QFLPs are 
subject to a 4SL:1 FL ratio and other conditions apply.  As at April 2012, six FLPs had been licensed under this scheme; 
(c) Joint Law Venture (JLV):  is a joint venture between an FLP with an SLP, which may be constituted as a partnership 
or company.  The JLV may practice Singapore law through SLs or FL's who have obtained a Foreign Practitioner 
Certificate (FPC) in "permitted areas" of legal practice (see above).  A JLV may market/publicise itself as a single service 
provider and bill clients as if it were a single law practice.  The constituent SLP of a JLV may share up to 49% of its total profits in the "permitted areas" with the constituent FLP.  If the JLV is a partnership, the number of FLP equity partners resident in Singapore must not exceed the number of SLP equity partners.  If the JLV is a corporation, the number of 
directors nominated by the FLP should not be greater than the number of those nominated by the SLP; 
(d) Formal Law Alliance (FLA) licence:  an FLP may collaborat e with an SLP to form an FLA.  The FLP and the SLP 
remain legally separate entities.  However, the FLA may ma rket/publicise itself as a single service provider.  The FLA 
may also prepare documents relating to cross-border transactions, including documents governed by Singapore law, and 
issue legal opinions relating to Singapore law through the SLP member of the FLA 
Accountancy services 
Legislation Accountants Act  
Regulatory bodies The Accounting and Corporate  Regulatory Authority (ACRA) and Public Accountants Oversight Committee (PAOC) a re 
responsible for registering an d regulating public accountants as we ll as other perm itted public accountin g entities (firms, 
corporations and limited liability partnerships (LLPs)) 
Membership of the professional association (the Institute of Certified Public Accountants of Singapore) is required 
Professions Public accountant inter alia  involves auditing and reporting on financial statements 
Qualification 
requirements  Professional examination;  at least three years practical experience, of which at least two years must be structured 
experience;  or six years practical experience (either structured or unstructured);  completion of at least 40 hours of continuing professional education in the 12 months immediately preceding the date of application;  completion of course on ethics and professional practice;  and demonstration of proficiency in local laws 
Recognition of qualifications and additional 
requirements for 
foreign accountants 
 Recognized foreign qualifications for registration:  the Institute of Chartered Accountants of Scotland (ICAS);  the 
Institute of Chartered Accountants in England and Wales (ICAEW);  the Institute of Chartered Accountants in Ireland (ICAI);  the Association of Chartered Certified Accountants (ACCA);  the Institute of Chartered Accountants in Australia 
(ICAA);  CPA Australia;  New Zealand Institute of Chartered Accountants (NZICA);  the Canadian Institute of Chartered 
Accountants (CICA);  the American Institute of Certified Public Accountants (AICPA);  and the Chartered Institute of Management Accountants of the United Kingdom (CIMA) 
Additional requirements:  foreign accountants must have at least three years of practical experience, of which at least one 
year must be local practical experience (up to two years of foreign experience may be considered if certain criteria are 
met);  and  pass examinations in Singapore company law and taxation, unless the applicant has at least 2 years of relevant local experience 
Selected 
requirements 
 Firms and LLPs:  two thirds of partnership must be public accountants (if the partnership has two partners, then one must 
be a public accountant) 
Corporations:  two-thirds of board of directors must be Singapore-registered public accountants;  two-thirds of voting 
shares must be owned by Singapore-registered public accountants 
No citizenship or residency requirements, except that a ll above-mentione d accounting entities must have at least one 
director or partner that is ordinarily resident in Singapore 
Engineering services 
Legislation Professional Engineers Act 
Regulatory bodies Professional Engineers Board, responsible for registration of engineers (which is mandatory in order to pract ice) and 
regulation of the profession 
Professions 
 The Professional Engineers Act regulates civil engineering, mechanical engineering, and electrical engineering.  There are 
also provisions for registered professional engineers in these branches to further register themselves as specialized 
professional engineers (currently in geotechnical engineering (a specialization of civil engineering) and amusement-ride 
engineering (a specialization of mechanical engineering)) 
 Table IV.11 (cont'd) 
 
  
  
  
  
  
  Singapore WT/TPR/S/267/Rev.1 
 Page 79 
 
 
    
Qualification 
requirements 
 Applicants applying to register with the Professional Engineers Board must meet qualification requirements (such as a 
degree in branches of engineering covered by the Act from the National University of Singapore or the Nanyang Technological University);  pass prescribed exams (the Fundamentals of Engineering and the Practice of Professional Engineering exams);  and have at least four years of practical experience  
Recognition of 
qualifications and additional requirements for 
foreign engineers 
 Qualifications from approved foreign universi ties and accredited by stipulated accrediting organizat ions are cons idered to 
meet qualification requireme nts under certain conditions.  Approved universities/accred iting organizations and the 
respective conditions applied are set out in the Professional Engineers (Approved Qualifications) Notification 2009.  These include institutions in:  Australia;  Belgium;  Canada;  China; Chinese Taipei;  France;  Germany;  Hong Kong, 
China;  India;  Ireland;  Japan;  Korea (Rep. of);  Malaysia;  the Netherlands;  New Zealand;  South Africa;  Sweden;  
Switzerland;  the United Kingdom;  and the United States 
Selected 
requirements 
 Multi-discipline partnership:   partnership must consist of only registered professional engineers and allied professionals  
LLP:  partners must be registered professional engineers, allied professionals, licensed corporations or licensed limited 
liability partnerships licensed under the PE Act, Architects Act or Land Surveyor Act 
Corporation:  simple majority of board of directors must be engineers registered with Professional Engineers Board or 
allied professionals 
No citizenship or residency requirements  
Architectural services 
Legislation Architects Act 
Regulatory bodies Board of Architects, responsible for registration of architects (which is mandatory in order to practice) and  regulation of 
the profession 
Professions Architect  
Qualification 
requirements Applicants applying to register with the Board must meet qualification requirements (Degree of Bachelor of Architecture 
from the National University of Singapore or the University of Singapore), pass the prescribed exams (the Professional 
Practice Examination) and have two years of practical experience in architectural work, including such practical 
experience in Singapore for a continuous period of minimum 12 months  
Recognition of qualifications Qualifications from certain approved schools of architecture are accepted in Singapore (these are listed at 
http://www.boa.gov.sg/education.html, and include schools in:  Au stralia;  Canada;  China;  England;  France; Germany;  
Hong Kong, China;  Ireland;  Japan;  New Zealand;  Northern Ireland;  Scotland;  United States;  and Wales).  Applicants 
applying to register with the Board must meet qualification requirements and pass the prescribed exams (the Professional Practice Examination) and have two years of practical experience in architectural work, including such practical experience in Singapore for a continuous period of minimum 12 months 
Selected requirements 
 Multi-discipline partnership and LLP:  no conditions 
Corporation:  simple majority of board of directors must be architects registered with Board of Architects No citizenship or residency requirements  
Source: Attorney-General's Chambers onl ine information.  Viewed at:  http://statutes.agc.gov.sg.  Singapore WT/TPR/S/267/Rev.1 
 Page 81 
 
 
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