TRW & Co · Real estate and stamp duty
ABSD for Companies, Trusts and Developers in Singapore

ABSD for companies in Singapore is 65% on any residential purchase, on top of Buyer's Stamp Duty, and the same rate applies to property placed in a living trust. Licensed housing developers pay 40% but can have 35% remitted if they build and sell on time. The decision on which route applies is fixed at signing.
Key pointIRAS ignores a change of intention after purchase: an entity that pays 65% cannot later claim the developer remission, and a developer that stops developing faces clawback with 5% interest.
At a glance
Entity rate is 65%
Companies, partnerships holding partnership property, unincorporated associations and similar entities pay 65% ABSD on any residential property bought on or after 27 April 2023.
Trusts pay 65% upfront
Transfers into a living trust attract ABSD (Trust) at 65%, refundable only where the beneficiaries are identifiable individuals with vested, unconditional interests.
Six-month refund window
A refund of ABSD (Trust) must be applied for within six months after the instrument is executed, and only after the full 65% has been paid.
Developer remission deadlines
Licensed developers must start within two years and complete and sell all units within five years to keep the 35% remission; 5% is never remitted.
Share deals are caught
Buying equity in an entity holding mainly Singapore residential property can attract Additional Conveyance Duties for significant owners, mirroring the direct duty.
Swipe or scroll →
The short answer: ABSD for companies in Singapore
ABSD for companies in Singapore is charged at 65% of the higher of the price and market value on any residential property an entity buys on or after 27 April 2023. The rate is the same for the first property as for the tenth, and it sits on top of Buyer's Stamp Duty. Transfers of residential property into a living trust attract ABSD (Trust) at the same 65%.
Two groups are treated differently. A licensed housing developer pays 40%, of which 35% can be remitted upfront if it builds and sells the units within set deadlines, while 5% is never remitted. A trustee holding property for identifiable individual beneficiaries pays 65% upfront but can apply for a refund down to the rate that the beneficiaries would have paid themselves.
This article explains who counts as an entity, how the trust and developer rules work, where the clawback risk sits, and how share purchases of property-holding companies are caught. Rates are taken from the IRAS ABSD page and match our guide to property acquisition in Singapore.

Who counts as an entity for ABSD
ABSD is imposed under the Stamp Duties Act 1929 and administered by the Inland Revenue Authority of Singapore (IRAS). IRAS defines an entity as a person who is not an individual. That plainly includes companies, wherever incorporated: a Singapore-incorporated company owned entirely by Singapore citizens is still an entity for ABSD, even though it may not be a foreign person under the Residential Property Act.
The definition also reaches arrangements that founders and families do not always think of as companies. IRAS lists:
- an unincorporated association;
- a trustee for a collective investment scheme, when acting in that capacity;
- a trustee-manager for a business trust, when acting in that capacity; and
- the partners of a partnership, whether or not any of them is an individual, where the property is to be held as partnership property.
The partnership point catches professional practices and family partnerships that buy a residential unit as a firm asset. If the property is held as partnership property, the 65% entity rate applies even though every partner is an individual who could have bought in their own name at a lower rate.
ABSD for companies in Singapore applies only to residential property. Commercial and industrial property carries Buyer's Stamp Duty but no ABSD, which is why operating businesses, funds and family offices usually hold offices, warehouses and retail space through companies without difficulty. The difficulty arises only when the asset is residential, including shophouses with a residential component.
Rates for companies, trusts and developers compared
| Buyer | 16 Dec 2021 to 26 Apr 2023 | On or after 27 Apr 2023 | Remission available |
|---|---|---|---|
| Entity (company, partnership property, unincorporated association) | 35% | 65% | No general remission |
| Trustee of a living trust | 35% (from 9 May 2022) | 65% | Refund if held for identifiable individual beneficiaries only |
| Licensed housing developer | 35% plus 5% non-remittable | 35% plus 5% non-remittable | 35% remitted upfront, subject to conditions |
| Trustee for a housing developer | Developer rate | Developer rate | As for the developer |
Both Buyer's Stamp Duty and ABSD are payable within 14 days after the contract is signed, or within 30 days of receipt in Singapore if signed overseas. Every buyer, including a housing developer, must complete the ABSD declaration form and keep it for at least five years in case IRAS asks for it.
For comparison, an individual Singapore citizen pays no ABSD on a first home, a permanent resident pays 5% and a foreigner pays 60%. Our article on foreigners buying property in Singapore explains the individual position, including the free trade agreement exception.
Trusts: ABSD (Trust) and the refund route
Since 9 May 2022, any conveyance, assignment or transfer on sale of residential property to a trustee to hold on a living trust attracts ABSD (Trust), now at 65%. The rate is the same as ABSD for companies in Singapore, which closed the gap that once made trusts an alternative to corporate ownership. The IRAS remission page sets out when part or all of it is refunded.
A refund is available only where the property is held on trust for one or more identifiable individual beneficiaries. The refund is the difference between the 65% paid and the ABSD that would have been payable based on the profile of the beneficial owner with the highest rate. The full 65% must be paid first, and the application must be made within six months after the instrument is executed.
Who is an identifiable individual beneficiary
An identifiable individual beneficiary is an individual named in the declaration of trust whose beneficial ownership is not revocable, variable or subject to a condition subsequent. The following do not qualify: someone not yet born when the trust is declared, someone entitled only to income, someone whose interest is contingent or discretionary, and someone who would benefit only if the trust is revoked. IRAS's own examples show that a gift to a child that vests only at 21, or a half share conditional on graduating, fails the test.
Two further points are often missed. First, the property counts towards the beneficiary's own property count, whether or not a refund is granted, so it affects the rate on their next purchase. Second, testamentary trusts created by a will and taking effect on death are outside ABSD (Trust), because the rules apply to living trusts. Our page on trusts and succession planning in Singapore covers the wider succession picture.
Housing developers: remission conditions and clawback
Developers pay ABSD at a lower, partly remittable rate because the Government wants land to be built on and sold, not held. For sites for five or more units, the IRAS remission conditions require the developer to be a company holding a housing developer's licence, to commence development within two years of acquisition and to complete the development and sell all units within five years. It must give IRAS a written undertaking and provide proof of commencement, completion and sales within those timelines.
If a condition is not met, the remitted ABSD becomes a debt to the Government with interest at 5% a year from 14 days after acquisition. Since 16 February 2024, the clawback for land acquired on or after 6 July 2018 is scaled by the proportion of units sold by the deadline, provided the commencement and completion conditions are met.
| Units sold by sale deadline | ABSD clawed back (before 5% interest) |
|---|---|
| 100% | None |
| 99% | 25% |
| 95% | 29% |
| 90% | 34% |
| Below 90% | 35% |
Large and complex projects can obtain longer timelines. Since 6 March 2025, qualifying complex projects receive six-month extensions, and for sites acquired on or after 29 July 2026 large en bloc redevelopments receive one or two additional years to complete and sell, depending on unit yield. The IRAS extensions page lists the categories, and our guide to the en bloc sale process explains how they interact with collective sales.
A separate remission applies to developments of four or fewer units, with its own conditions. Smaller developers redeveloping a single landed plot should check that route rather than assume the five-unit rules apply.
Holding companies and conveyance directions
Groups often sign for a site in a holding company and then direct the transfer to a project company. In that case the holding company is charged at the 65% entity rate, which may be remitted upfront only if strict conditions are met: a clear intention at contract to transfer to a housing developer it has incorporated or will incorporate, a conveyance direction made within two months of the contract, no consideration passing, and a beneficial interest of more than 50% in the developer held until completion.
Additional sites bought on or after 6 February 2023 for a single development with an existing site have their own rules, with the sale obligation calculated pro rata to land area.
Intention is fixed at the point of purchase
The most expensive mistake in this area is a change of plan. IRAS states that the purchasing entity must decide at the point of purchase whether it will undertake housing development of the property. Any later change of intention is not considered. An entity that pays 65% and later decides to redevelop and sell will not qualify for the developer remission, even if it then meets every condition.
The reverse is also true. A company that claims the developer rate and then decides to hold and lease the property will face clawback with interest. ABSD for companies in Singapore therefore needs a board decision, recorded before the option is exercised, on what the company will do with the property, supported by a feasibility study, financing and a licence application timetable.
Minute the board's decision on housing development before the option to purchase is exercised, and align the entity, licence and financing with that decision. IRAS will not revisit the ABSD rate because the plan changed after signing.
Buying shares instead of property: Additional Conveyance Duties
Buying the shares of a company that owns residential property does not avoid the duty. Additional Conveyance Duties (ACD) apply to acquisitions and disposals of equity interests in property-holding entities by significant owners. An entity is a property-holding entity where at least half of its total tangible assets consist of prescribed immovable property in Singapore, broadly property zoned or used for residential or mixed residential purposes. Indirect holdings through subsidiaries can qualify too.
ACD on the buyer side is designed to mirror the stamp duty differential between buying the property directly and buying the company. On the seller side, ACD applies where a significant owner disposes of equity within a holding period; for interests acquired on or after 4 July 2025, that period is four years. In a share deal for a residential portfolio, ACD should be modelled alongside warranties, tax indemnities and the target's own historic stamp duty position.
Our stamp duty team reviews ACD exposure as part of acquisition structuring and due diligence.
Cross-border buyers and group structures
Overseas groups from Bangladesh, the UK, the UAE and China often hold Singapore assets through a Singapore holding company for tax and governance reasons. That works well for commercial property, but a residential acquisition through the same company attracts 65% ABSD and, for landed property, may also need approval as a foreign person. Group structures should separate residential holdings from operating assets and be reviewed with our tax structuring team before any purchase.
Where a foreign family uses a trust, the trustee's location does not change the analysis: the transfer to a trustee is chargeable, and any refund depends on the beneficiaries being identifiable individuals with vested interests.
Illustrative scenario: a family holding company and a new home
This scenario is illustrative only; the parties are generic.
A family investment company owns several commercial units, on which it paid no ABSD. The founder proposes that the company buy a condominium for a grown-up child, on the basis that the company has cash and the child does not.
The advisers point out that ABSD for companies in Singapore would be 65% of the price. They compare three alternatives. If the child buys directly as a Singapore citizen with no other residential property, no ABSD is payable. If a parent buys and holds on a bare trust for the child, with vested and unconditional beneficial ownership, 65% is paid upfront but can be refunded in full if the application is made within six months. A discretionary trust would not qualify for a refund.
The family chooses a funded purchase by the child, documented with a loan agreement from the company, and records the property in the child's property count for future planning.
Risks and common mistakes
Assuming a Singapore company escapes ABSD
Being incorporated in Singapore, or owned by Singapore citizens, does not change the ABSD rate. Every entity pays 65% on residential property. Some buyers confuse ABSD with the Residential Property Act, under which a Singapore company whose directors and members are all citizens is not a foreign person. The two regimes are separate. Check both before choosing a holding vehicle for any residential asset.
Drafting a trust that fails the refund conditions
A trust that gives the trustee discretion, delays vesting, makes an interest conditional or allows the settlor to revoke it will not qualify for a refund of ABSD (Trust). The 65% then stays paid. If the aim is to hold property for a child or spouse at their own ABSD rate, the declaration of trust must give vested, unconditional beneficial ownership from the outset. Draft and review it before the purchase instrument is signed, because the instrument and trust are tested at execution.
Missing the six-month refund deadline
The refund application for ABSD (Trust) must be made within six months after the instrument is executed, and the 65% must already have been paid. Families who complete a purchase and only later approach IRAS can lose the refund entirely. Diarise the deadline at signing, prepare the trust instrument and purchase documents in advance, and file through myTax Portal as soon as the duty is paid.
Underestimating the developer clawback
A developer that sells 95% of its units by the deadline still repays a substantial part of the remitted ABSD, plus interest. Market slowdowns, construction delays and unsold larger units all feed into that risk. Model the clawback as a contingent cost in the feasibility study, check whether the site qualifies for an extension category, and consider pricing strategies that clear the last units before the deadline.
Overlooking partnership and association purchases
A residential unit bought as partnership property, or by a club or association, is charged at the entity rate even where the people involved are individuals. If the property is genuinely for an individual's use, it may be better bought by that individual, with any business arrangements documented separately.
Step-by-step checklist for ABSD for companies in Singapore
Work through these steps before any entity, trustee or developer signs an option to purchase residential property.
- Classify the buyer. Decide whether the buyer is an entity, a trustee of a living trust or a licensed housing developer, and record the basis.
- Fix the intention. For a developer, minute the board's decision to develop and sell, and confirm the licence and any Qualifying Certificate timetable.
- Test the deadlines. Check that commencement within two years and completion and sale within five years are realistic, and whether an extension category applies.
- Settle the trust terms. If a trust is used, confirm that every beneficiary is an identifiable individual with a vested, unconditional interest before signing.
- Check share deals for ACD. If shares are being bought, test whether the target is a property-holding entity and whether the buyer becomes a significant owner.
- Fund and stamp on time. Arrange funds for BSD and ABSD and stamp within 14 days of signing, or 30 days of receipt if signed overseas.
- Diarise refunds and reporting. Diarise the six-month ABSD (Trust) refund deadline and the developer's evidence deadlines, and keep the ABSD declaration form for at least five years.
ABSD for companies in Singapore is unforgiving because the rate is fixed at signing. To review a proposed acquisition or holding structure, please contact TRW & Co.
Frequently asked questions
01What is the ABSD rate for companies buying residential property in Singapore?
Entities pay ABSD at 65% on any residential property purchased on or after 27 April 2023, calculated on the higher of the price and market value. This is in addition to Buyer's Stamp Duty. The rate does not depend on how many properties the company already owns or who its shareholders are. Commercial and industrial property does not attract ABSD, which is why most corporate real estate holdings are non-residential.
02Does a Singapore company owned by citizens pay less ABSD?
No. For ABSD, any person who is not an individual is an entity and pays the entity rate, regardless of where it is incorporated or who owns it. The ownership of the company matters for a different regime, the Residential Property Act, which governs whether a buyer needs approval to acquire landed residential property. A company can be a Singapore company under that Act and still pay 65% ABSD.
03Can I get ABSD (Trust) refunded if I buy property on trust for my child?
Possibly. IRAS refunds the difference between the 65% paid and the rate that would apply to the beneficiary with the highest ABSD profile, if the property is held on trust only for identifiable individual beneficiaries. The child's beneficial ownership must be vested and not revocable, variable or conditional. A trust where the interest vests only at a later age, or depends on a condition, does not qualify. The application must be made within six months after the instrument is executed.
04What happens if a housing developer does not sell all units in five years?
The remitted ABSD is clawed back, with interest at 5% a year from 14 days after the acquisition date. For land acquired on or after 6 July 2018, the clawback is scaled by the proportion of units sold by the deadline, provided commencement and completion conditions are met. For land acquired on or after 16 December 2021, selling 99% reduces the clawback to 25%, and selling below 90% means the full 35% is clawed back.
05Can a company change its mind and claim the developer ABSD rate later?
No. IRAS requires the purchasing entity to decide at the point of purchase whether it will undertake housing development, and any later change of intention is not considered. An entity that has paid the 65% rate will not qualify for the housing developer remission even if it later meets the conditions. Boards should record their decision before exercising an option to purchase.
06Does ABSD apply to property left in a will on trust?
ABSD (Trust) applies to transfers into living trusts, meaning trusts created by a settlor during their lifetime. IRAS has confirmed that a testamentary trust, created by a will and taking effect after death, is not a living trust and is not subject to ABSD (Trust). Other stamp duty and estate administration rules still apply, so the will should be drafted with succession advice.
Sources and official materials
- IRAS: Additional Buyer's Stamp Duty (ABSD) — Rates, entity definition, trusts and developer rates
- IRAS: Remission of ABSD (Trust) — Refund conditions for identifiable individual beneficiaries
- IRAS: Sites for development of five or more residential units — Housing developer remission conditions and scaled clawback
- IRAS: ABSD remission timeline extensions — Extensions for complex projects and large en bloc sites
- IRAS: Overview of Additional Conveyance Duties — Duties on equity interests in property-holding entities
- Stamp Duties Act 1929 — Statutory basis for BSD, ABSD and ACD
General information only, current as at 20 October 2026. It is not legal advice and does not create a lawyer–client relationship. Singapore law and regulatory practice change; check current official sources and take advice on the facts of your matter.



