Tax residency and Singapore substance
Singapore's headline corporate tax rate is 17%. Whether your company gets the benefits of being a Singapore company, including treaty relief on royalties from other countries, depends on where it is managed. IRAS applies the control and management test: a company is resident in Singapore if its board actually makes the strategic decisions here. Getting that test to come out right is a set of habits, not a document.
Control and management
The test is where the board works, not where the money sits. A company is resident in Singapore when its board actually makes the strategic decisions here. That means meetings in Singapore, records of what was decided, and directors who are present for the decisions, not just on the letterhead. A holding company that collects royalties but decides nothing will struggle to claim the residency its paperwork says it has. The paperwork follows the decisions. It cannot replace them.
The certificate
A resident company can apply to IRAS for a Certificate of Residence. It is the document foreign licensees and tax authorities expect before they apply treaty rates to the royalties moving out of their country. What backs the application is substance: a resident director, a local company secretary, a registered office, board meetings held in Singapore, and filings made on schedule. None of that is optional paperwork. It is the difference between a company that can claim treaty relief and a company that can only ask for it.