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Overview

Individuals who hold units as investment assets and not as trading assets, excluding individuals who hold units through a partnership in Singapore, are exempt from income tax on taxable income distributions, regardless of their nationality or tax residence status.

Individuals who hold units as trading assets or through a partnership in Singapore are subject to income tax on taxable income distributions. The gross amount of such distributions (i.e., before tax deducted at source, if any) is taxable in the hands of the individuals at their own applicable income tax rate.

Qualifying non-resident non-individual unitholders and qualifying non-resident funds are subject to Singapore income tax on taxable income distributions. The tax is imposed on the gross amount of such distributions (i.e., before tax deducted at source) at the prevailing tax rate (currently 17.0%) except for distributions made on or before 31 December 2030 (as proposed in the 2025 Singapore Budget) where the tax rate is reduced to 10.0%.

Unless otherwise exempt or reduced, non-individual unitholders (other than qualifying non-resident non-individual unitholders and qualifying non-resident funds) are subject to Singapore income tax on taxable income distributions, regardless of whether the Trustee and the Manager had deducted tax from the distributions. The gross amount of such distributions (i.e., before tax deducted at source (if any)) is taxable at the prevailing tax rate (currently 17.0%).

A "Qualifying Non-resident Non-individual Unitholder" is a unitholder who is neither an individual nor a resident of Singapore for income tax purposes and who:

  • does not have any permanent establishment in Singapore; or
  • carries on any operation through a permanent establishment in Singapore, where the funds used by that person to acquire the Units are not obtained from that operation.

A "Qualifying Non-resident Fund" is a non-resident fund which qualifies for tax exemption under Section 13D, 13U or 13V of the Singapore Income Tax Act 1947 and which:

  • does not have any permanent establishment in Singapore (other than a fund manager in Singapore); or
  • carries on any operation through a permanent establishment in Singapore (other than a fund manager in Singapore), where the funds used by the fund to acquire the units are not obtained from that operation.

For this purpose, a non-resident fund refers to a fund being a non-resident company, a partnership where all partners are non-residents, a trust administered by a non-resident trustee, or a non-resident entity.

If you are a non-U.S. Unitholder, you must comply with certain documentation requirements in order to be exempted from withholding tax on U.S. source interest and/or, where applicable, U.S. source dividends under the U.S. Tax Code, including under the United States Foreign Account Tax Compliance Act ("FATCA") and the U.S. Treasury regulations and administrative guidance promulgated thereunder. Specifically, you must establish, as applicable, your (i) status for FATCA purposes by providing an applicable IRS Form W-8 and/or such other certification or other information related to FATCA to establish exemption from withholding under FATCA that is requested from time to time, (ii) if applicable, your claim for a reduced withholding tax rate under a double tax treaty as evidenced by an applicable IRS Form W-8 and (iii) your eligibility for the Portfolio Interest Exemption by providing an applicable IRS Form W-8 and a U.S. Tax Compliance Certificate in the form set out in the Trust Deed and/or such other information related to such exemption that is requested from time to time. U.S. source payments of interest and dividends paid by a U.S. REIT to NTT DC REIT through SG Sub 2 and SG Sub 3, as applicable may be eligible for relief under an applicable U.S. double tax treaty if your jurisdiction of tax residence views NTT DC REIT and SG Sub 2 and/or SG Sub 3, as applicable as a fiscally transparent entity under its local laws. The rules on double tax treaty eligibility are complex, and you should consult with your own tax adviser regarding these rules in light of your specific circumstances.

You must also provide updates of any changes to your status for the purposes of FATCA and the Portfolio Interest Exemption including information relating to your name, address, citizenship, personal identification number or tax identification number, tax residencies, and tax status. Such information may be disclosed or reported to the IRS, the Inland Revenue Authority of Singapore or other applicable tax or regulatory authorities for the purpose of compliance with U.S. tax laws and regulations. If you fail to provide or to update relevant information necessary for compliance with U.S. tax withholding requirements, including any exemption from FATCA withholding and the Portfolio Interest Exemption, or provide inaccurate, incomplete or false information, amounts payable by NTT DC REIT to you may be subject to deduction or withholding in accordance with U.S. tax law and any intergovernmental agreements.