Tax residence in China for Singapore taxpayers

China treats as resident anyone with a domicile in China and anyone without domicile who spends 183 days there in the calendar year, counting only full 24-hour days. A resident without domicile is taxed on foreign income paid from abroad only after six qualifying years. Singapore uses the same calendar year but other tests, so dual residence arises mainly through domicile, normal residence or the IRAS two- and three-year rules; Art. 4(2) of the Singapore–China Agreement then decides.

Check your status: Singapore and China

Free, no sign-up, about 3 minutes. Conclusion under Singapore's Income Tax Act 1947, compared with the law of China and the tax treaty (DTA).

When China treats you as a tax resident

China does not use nationality: Chinese and foreign nationals are resident if they have a domicile in China — habitual residence by reason of household registration (hukou), family or economic interests — or, without a domicile, reside in China for 183 days or more in the calendar year. Domicile is a legal standard: a person abroad temporarily for study, work, family visits or travel who returns to live in China when the reason ends keeps China as the place of habitual residence.

An individual without domicile becomes a resident individual with an aggregate of 183 days in China in the calendar year (the 183rd day included). Only days with a full 24 hours in China count — China counts over the calendar year (1 January – 31 December).

The «six-year rule» does not change resident status; it only decides whether foreign-source income of a resident without domicile that is paid by foreign entities or individuals is taxed in China.

You habitually reside in China by reason of household registration, family or economic interests, so you have a domicile in China. Under Art. 1 of the Individual Income Tax Law you are a Chinese resident individual taxed on your worldwide income, whatever the number of days you spent in China; tax paid abroad is credited within the limit of Art. 7.
You have no domicile in China, but you resided there for 183 days or more in the calendar year, so you are a Chinese resident individual (Art. 1). Because in each of the six preceding years you also had 183 days without a single absence of more than 30 days, all your income — from China and from abroad, including Singapore — is taxable in China.
You have no domicile in China, but you resided there for 183 days or more in the calendar year, so you are a Chinese resident individual (Art. 1). Because in at least one of the six preceding years you had fewer than 183 days or a single absence of more than 30 days, your foreign-source income paid by foreign entities or individuals — for example income from Singapore paid by a Singapore payer — is exempt in China after filing a record with the tax authority (Regulations Art. 4). Chinese-source income, including pay for work in China, and foreign income paid by a Chinese entity remain taxable.
You have no domicile in China, but you resided there for 183 days or more in the calendar year, so you are a Chinese resident individual (Art. 1). Whether China also taxes your foreign income depends on the six-year rule: if in each of the six preceding years (counted from 2019) you had 183 days without a single absence of more than 30 days, all income is taxable; otherwise foreign-source income paid by foreign entities or individuals is exempt after filing a record.
You resided in China for 183 days or more in the calendar year, so you are a Chinese resident individual whether or not you have a domicile there (Art. 1). With a domicile, all your income is taxable in China; without one, foreign-source income paid by foreign entities or individuals may be exempt under the six-year rule (Regulations Art. 4).

When you are a non-resident

You have no domicile in China and resided there for fewer than 183 days in the calendar year, so you are a non-resident individual (Art. 1): China taxes only your income from sources in China. Pay for work done outside China is not Chinese-source; with not more than 90 days in China, the part of pay for China work that is paid by a foreign employer and not borne by its establishment in China is exempt (Regulations Art. 5).

Where the rules of China clash with Singapore tax rules

Collision: China treats you as resident because of domicile. China treats an individual with a domicile in China — habitual residence by reason of hukou, family or economic interests — as resident whatever the number of days in China. If you keep a Chinese domicile while working in Singapore and spend 183 days in Singapore in the calendar year (or are resident there under the IRAS two- or three-year rules), both countries claim you. Art. 4(2) of the Singapore–China Agreement decides: permanent home; with a home in both countries, the centre of vital interests; if that cannot be determined, or you have a permanent home in neither, habitual abode; then nationality; then mutual agreement.
Collision: 183 days in China in the calendar year while resident in Singapore. Without a domicile in China, 183 days in China in the calendar year make you a Chinese resident individual. Both countries use the calendar year, so you cannot normally have 183 days in each; the overlap arises when Singapore treats you as resident without 183 days — as a citizen or permanent resident who normally resides in Singapore and is temporarily absent, or as a foreign employee under the IRAS two- or three-year rules. Art. 4(2) of the Singapore–China Agreement then decides which country is your state of residence, and with it whether China may tax your income from Singapore.

What else to know

Same calendar year, different ways of counting days. Both China and Singapore decide residence for the calendar year (1 January – 31 December); in Singapore that year is the basis period of the following Year of Assessment. They count days differently: China counts only days with a full 24 hours in China, while IRAS counts days of physical presence or employment in Singapore, including weekends, public holidays and temporary absences connected with your Singapore employment. The 183-day limit for salary in Art. 15(2)(a) of the Singapore–China Agreement is not tied to either tax year: it is counted within any twelve-month period.
Income from Singapore of a Chinese resident without domicile: the six-year rule. If you are resident in China only under the 183-day test, China does not tax your foreign-source income paid by foreign entities or individuals — for example rent from property in Singapore, interest on Singapore bank accounts, or salary for work done in Singapore paid by a Singapore employer — unless in each of the six preceding years (counted from 2019) you had 183 days in China with no single absence of more than 30 days. The exemption requires filing a record with the competent tax authority. Pay for work done in China is Chinese-source even if a Singapore employer pays it.
How Singapore relieves double taxation of Chinese income. If Singapore is your state of residence, it generally does not tax your Chinese income: foreign-sourced income not brought into Singapore is outside the charge (s. 10(1) ITA 1947), and foreign-sourced income received in Singapore by a resident individual is exempt (s. 13(7A)), except through a partnership in Singapore. Where Chinese income is taxable in Singapore, the Chinese tax is credited (Art. 22(2)) — at most the Singapore tax on that income. If China is your state of residence, China credits Singapore tax on income from Singapore against Chinese tax on the same income, up to the Chinese tax on it (Art. 22(1)).
Working in China while resident in Singapore: the 183-day rule (Art. 15(2)). Pay for work physically done in China is Chinese-source wherever it is paid. If Singapore is your treaty residence, China does not tax it only if all three conditions of Art. 15(2) are met: you are in China for not more than 183 days in aggregate within any twelve-month period; the employer is not resident in China; and the pay is not borne by a permanent establishment or fixed base of the employer in China. Chinese domestic law on its own exempts pay from a foreign employer only up to 90 days (Regulations Art. 5).
Year of arrival or departure: no split year in either country. Neither country splits its tax year: China and Singapore both decide residence for the whole calendar year. In the year you move you can therefore be resident in both countries — for example as a foreign employee under the IRAS two-year rule — and the Agreement's tie-breaker applies to the period of dual residence. Keep entry and exit records — China counts only days with a full 24 hours in China.

How dual residence is resolved

If both countries treat you as a resident, Art. 4(2) of the treaty applies: Agreement between the Government of the Republic of Singapore and the Government of the People's Republic of China for the avoidance of double taxation and the prevention of fiscal evasion with respect to taxes on income (signed at Singapore on 11 July 2007), with Protocol, as amended by the Second Protocol of 24 August 2009 and the Third Protocol of 23 July 2010 and modified by the MLI. The tests are applied in order — permanent home, centre of vital interests, habitual abode, nationality, and finally mutual agreement between the tax authorities.

The treaty in detail: income, rates, the 183-day rule →

Terms you will come across in China

domicile (zhùsuǒ): habitual residence in China by reason of household registration, family or economic interests — makes you resident whatever the days
resident individual (jūmín gèrén): taxed in China on worldwide income
183 days: days in China in the calendar year; only days with a full 24 hours in China count
six-year rule: a resident without domicile is exempt on foreign income paid from abroad unless six prior years each had 183 days without a 30-day absence
comprehensive income: wages, service fees, author's remuneration and royalties taxed together at 3%–45%
hukou: Chinese household registration — one of the factors of domicile

Questions

Does China tax my Singapore income if I live in China?

If you have no domicile in China and are resident only under the 183-day test, foreign income paid by foreign payers is exempt after filing a record, unless you have completed six qualifying years in a row.

Does China tax my salary for a short China assignment?

If Singapore is your treaty residence, not when all conditions of Art. 15(2) are met: not more than 183 days within any twelve-month period, an employer not resident in China, and pay not borne by a Chinese permanent establishment.

How is double taxation relieved?

Singapore generally does not tax foreign-sourced income of resident individuals; where it does, it credits Chinese tax (Art. 22(2)). China credits Singapore tax up to the Chinese tax on that income (Art. 22(1)).

Sources

Legislation and official guidance

Individual Income Tax Law of the People's Republic of China (seventh amendment of 31 August 2018), Art. 1 — An individual who has a domicile in China, or who has no domicile but resides in China for an aggregate of 183 days or more in a tax year, is a resident individual and is taxed on income from inside and outside China. An individual with neither domicile nor residence in China, or with no domicile and fewer than 183 days, is a non-resident individual taxed only on income from inside China. The tax year is the calendar year (1 January – 31 December).
Implementation Regulations of the Individual Income Tax Law (State Council Decree No. 707), Art. 2 — Having a domicile in China means habitually residing in China by reason of household registration (hukou), family or economic interests.
Provisions on Several Issues concerning the Levy of Individual Income Tax (Guoshuifa [1994] No. 89), Art. 1 — Habitual residence is a legal standard for deciding whether a taxpayer is resident or non-resident; it does not mean the place of actual residence or of residence in a particular period. A person who lives abroad for study, work, family visits or travel and must return to live in China once the reason ends has China as the place of habitual residence.
MOF/STA Announcement No. 34 of 2019 — For an individual without domicile, days of residence are the days of stay in China: a day with a full 24 hours in China counts, a shorter stay does not. If such an individual resides 183 days in a tax year and in each of the six preceding years also had 183 days with no single departure of more than 30 days, both Chinese-source and foreign-source income is taxable for that year; otherwise foreign-source income paid by foreign entities or individuals is exempt. The six years are counted from 2019 onward.
Implementation Regulations of the Individual Income Tax Law, Art. 4 — An individual without domicile who has resided in China for 183 days in each of fewer than six consecutive years is, after filing a record with the competent tax authority, exempt on foreign-source income paid by foreign entities or individuals; a single departure of more than 30 days in any year restarts the count.
Implementation Regulations of the Individual Income Tax Law, Art. 3 — Unless otherwise provided, income from services performed in China through office, employment or performance of a contract is income from sources in China, wherever it is paid.
Implementation Regulations of the Individual Income Tax Law, Art. 5 — An individual without domicile who resides in China for an aggregate of not more than 90 days in a tax year is exempt on the part of Chinese-source employment income that is paid by a foreign employer and not borne by the employer's establishment or place in China.
MOF/STA Announcement No. 3 of 2020 (individual income tax on foreign-source income) — Income from services performed outside China is foreign-source income. Foreign comprehensive and business income is combined with domestic income of the same kind; other categories are computed separately. The credit limit is computed per country (region); excess credit can be carried forward for five tax years; no credit without a qualifying tax certificate; tax spared under a treaty is treated as paid. Residents declare foreign income between 1 March and 30 June of the following year. Where the foreign tax year differs from the calendar year, the calendar year in which the foreign tax year ends is the corresponding year.
s. 2(1) ITA 1947 (definitions of «year of assessment» and «basis period»); IRAS — preceding-year basis of assessment — Tax is charged for a year of assessment (YA) on the income of the preceding calendar year: YA 2027 covers income from 1 January to 31 December 2026. Residence is determined for the same preceding calendar year, so the selected year 2026 is the basis year for YA 2027.
IRAS — «Working out my tax residency» (updated 12 May 2026) — A Singapore citizen or permanent resident who normally resides in Singapore, except for temporary absences, is a tax resident. A foreigner is resident for a year of assessment if, in the preceding calendar year, he or she stayed or worked in Singapore for at least 183 days, or stays or works in Singapore continuously for three consecutive years (then for all three years, even with fewer than 183 days in the first and third). A foreign employee whose employment spans two calendar years is resident for both years if the period of employment, together with the stay immediately before and after it, is a continuous period of at least 183 days (not for company directors, public entertainers and professionals). Days include weekends and public holidays, and temporary absences (leave abroad, business trips) connected with the employment in Singapore.
Art. 15(2) of the Singapore–China Agreement — Remuneration of a resident of one State for employment exercised in the other State is taxable only in the first State if (a) the recipient is present in the other State for a period or periods not exceeding in the aggregate 183 days within any twelve-month period, (b) the remuneration is paid by, or on behalf of, an employer who is not a resident of the other State, and (c) it is not borne by a permanent establishment or fixed base which the employer has in the other State.
Art. 4(2) of the Singapore–China Agreement — Dual-resident individual: (a) resident of the State in which he has a permanent home available to him; if he has a permanent home in both States, of the State with which his personal and economic relations are closer (centre of vital interests); (b) if the centre of vital interests cannot be determined, or he has no permanent home available in either State, of the State in which he has an habitual abode; (c) habitual abode in both States or in neither — the State of which he is a national; (d) in any other case, the competent authorities settle the question by mutual agreement. The MLI did not change Art. 4(2).
Art. 22(1)–(2) of the Singapore–China Agreement — China (Art. 22(1)): Singapore tax payable on income from Singapore is credited against Chinese tax on that income, not exceeding the Chinese tax on it. Singapore (Art. 22(2)): credit for Chinese tax against Singapore tax. The Agreement has no remittance clause.
s. 10(1) ITA 1947 — Income tax is payable on the income of any person accruing in or derived from Singapore or received in Singapore from outside Singapore — including gains or profits from any trade, business, profession or vocation, from any employment, dividends, interest, rents, royalties and pensions.
s. 13(7A) ITA 1947 — Exempt is income from sources outside Singapore received in Singapore: (a) by a non-resident individual; (b) from 1 January 2004 — by a resident individual, where the Comptroller is satisfied that the exemption is beneficial to him or her; the exemption does not cover such income received through a partnership in Singapore.
IRAS — «Claiming foreign tax credit» — Where foreign income is taxable in Singapore and foreign tax has been paid on it, a resident can claim a foreign tax credit in the return; the credit is the lower of the foreign tax paid and the Singapore tax payable on that income.
Implementation Regulations of the Individual Income Tax Law, Arts 21–22 — The credit limit is computed separately for each country (region). If tax paid in a country is lower than the limit, the difference is paid in China; the excess can be credited against the unused limit for the same country in later years, for at most five years. A credit claim requires the tax payment certificate issued by the foreign tax authority for the year concerned.
ITA 1947, s. 2(1) («resident in Singapore»), 62(4)–(5), 73(1); IRAS — «Working out my tax residency» (updated 12 May 2026) — Status is set for the whole calendar year and applies to the following Year of Assessment. A foreigner arriving is resident for that year with 183 days of presence or employment, or under the two-year or three-year administrative rules; a holder of a work pass valid for at least one year is provisionally treated as resident, and the status is reviewed at tax clearance. A person chargeable to tax notifies IRAS within one month of arrival.
Individual Income Tax Law, Art. 3 and rate schedules — Comprehensive income: progressive rates of 3% to 45% (annual taxable income up to ¥36,000 — 3%; ¥36,000–144,000 — 10%; ¥144,000–300,000 — 20%; ¥300,000–420,000 — 25%; ¥420,000–660,000 — 30%; ¥660,000–960,000 — 35%; above ¥960,000 — 45%). Business income: 5% to 35%. Interest, dividends, rental income, gains from transfer of property and incidental income: 20%.
Individual Income Tax Law, Art. 6 — Taxable comprehensive income of a resident individual: annual income less ¥60,000 and special, special additional and other deductions. Non-resident individual: monthly wages less ¥5,000; remuneration for personal services, author's remuneration and royalties per payment.
Individual Income Tax Law, Art. 7 — A resident individual may credit individual income tax paid abroad on income from outside China against the Chinese tax payable, but not beyond the Chinese tax on that foreign income computed under the Law.
Individual Income Tax Law, Arts 10, 11 and 13 — Filing is required, among other cases, for foreign-source income and for non-resident individuals with wages from two or more sources in China. Comprehensive income is withheld in advance monthly or per payment and reconciled between 1 March and 30 June of the following year; foreign-source income is declared between 1 March and 30 June of the following year; tax on a non-resident's wages is withheld by the payer with no annual reconciliation.
Art. 4(2)(a) of the Singapore–China Agreement — A dual-resident individual is deemed to be a resident only of the State in which he has a permanent home available to him; if he has a permanent home available in both States, of the State with which his personal and economic relations are closer (centre of vital interests).
State Taxation Administration — Singapore treaty page (Agreement 2007, Second and Third Protocols, MLI synthesised text) — Official Chinese publication of the 2007 Agreement and its Protocols in Chinese and English; treaty list: signed 2007-07-11, in force 2007-09-18, effective 2008-01-01.
Art. 4(2)(b) of the Singapore–China Agreement — If the State of the centre of vital interests cannot be determined, or if he has no permanent home available in either State, he is deemed to be a resident only of the State in which he has an habitual abode.
Art. 4(2)(c), (d) of the Singapore–China Agreement — If he has an habitual abode in both States or in neither, he is deemed to be a resident only of the State of which he is a national (c); in any other case the competent authorities settle the question by mutual agreement (d).

Updated 10/11/2026. The result is for information only and is not tax or legal advice. IRAS, other tax authorities and courts may interpret the rules differently, including because of circumstances not covered here, and the law can change with each annual Budget. Consult a qualified adviser before making decisions.

Check your status