Groups that centralise funding, cash pooling and FX can base that function where incentives exist. Singapore offers a Finance and Treasury Centre rate of 8% or 10%, UAE free zones can give 0% on related-party treasury income, India's IFSC offers a long tax holiday, and Saudi Arabia offers 0% to licensed regional headquarters. The 15% minimum tax now limits the value of these incentives for large groups.
What each location offers
Singapore's Finance and Treasury Centre incentive taxes income from approved activities, such as treasury and fund management and corporate finance services to group companies, at 8% or 10%, and can exempt interest paid to overseas banks and approved network companies from withholding. Since 13 February 2026 certain payments akin to interest may also qualify.
In the UAE, a Qualifying Free Zone Person pays 0% on qualifying income, which includes treasury and financing services to related parties, provided it has real substance in the free zone and its non-qualifying revenue stays within the lower of 5% of revenue or AED 5 million. India's IFSC units can claim a 100% exemption for 20 years out of 25, and loans between an IFSC global treasury centre and group entities of a listed foreign parent are excluded from deemed dividend rules. Dividends from an IFSC unit to a foreign company are taxed at 10% rather than 20%. A licensed Saudi regional headquarters pays 0% on eligible income for 30 years but must meet staffing and activity milestones.12345678910
Substance and the minimum tax
Every regime requires real activity: UAE free zone status is lost for the whole period if conditions fail, and a Saudi regional headquarters must employ at least 15 full-time staff within a year. For groups with revenue of EUR 750 million or more, Singapore and the UAE now apply domestic top-up taxes at 15% from 2025, so a low incentive rate may simply move tax from one line to another.3101112
| Location | Regime | Rate on qualifying income | Key condition | Source |
|---|---|---|---|---|
| Singapore | Finance and Treasury Centre | 8% or 10% | EDB award; approved activities | PwC (secondary); EDB |
| UAE free zones | Qualifying Free Zone Person | 0% (9% on other income) | Substance; de minimis lower of 5% or AED 5 million | Ministry of Finance law; PwC |
| India (GIFT City IFSC) | IFSC unit incentive | 100% exemption for 20 of 25 years | IFSC unit; concessional rates outside holiday | PwC (secondary) |
| Saudi Arabia | Regional headquarters | 0% for 30 years | MISA licence; 15 staff within one year | ZATCA; MISA |
Decisions to make
- Is the group within the 15% minimum tax?1112If so, domestic top-up taxes in Singapore and the UAE can neutralise low incentive rates.
- Where will the treasury team actually sit and take decisions?310Free zone and regional headquarters incentives depend on substance and staffing in that location.
- Will the centre earn income from third parties or onshore customers?5UAE non-qualifying revenue above the de minimis can remove the 0% rate.
- Will the centre borrow from overseas banks?2Singapore's incentive can remove withholding tax on that interest.
Documents usually needed
- Incentive application and award letter (EDB, MISA or IFSCA as relevant)
- Treasury policy and delegation of authority showing local decision-making
- Transfer pricing documentation for treasury services and intra-group financing
- Substance evidence: employment contracts, office lease, local board minutes
- Pillar Two impact analysis for in-scope groups
Common mistakes
- Choosing a location for its headline rate without modelling the 15% top-up tax
- Booking treasury income in a free zone entity whose staff and decisions are elsewhere
- Letting third-party income push a UAE free zone entity over the de minimis
- Assuming an EDB incentive is automatic rather than awarded case by case
What this guide does not yet confirm
These points need checking with a qualified local professional before you rely on them.
- The Singapore FTC incentive's expiry date and the UAE ministerial decisions on qualifying activities could not yet be checked on official pages.
- IFSCA regulations for global and regional corporate treasury centres and the Income-tax Act, 2025 section numbers for IFSC incentives were not confirmed.
- Whether treasury activities qualify as Saudi regional headquarters eligible activities was not confirmed.
- No treasury-specific incentives were researched for the UK, US, Germany or France.
Sources and review status
Each statement is numbered to the source it was checked against. We use official sources where we can, and each statement says whether it was checked against an official or a secondary source. Sources last checked on 19 October 2026. None of it has been professionally reviewed yet: it is research checked against official and secondary sources by WONE Global, not legal or tax advice.
Income derived by an approved Singapore Finance and Treasury Centre from approved activities is taxed at a reduced rate of 8% or 10%. Approved activities include international treasury and fund management, corporate finance and advisory services, economic and investment research, and credit control. Award is case by case through the Economic Development Board; the current expiry date of the scheme was not confirmed.
Secondary source; the EDB incentives page names the scheme but does not state its rate.
Interest paid by a Singapore Finance and Treasury Centre to overseas banks and approved network companies on funds used for approved activities can be exempt from withholding tax, and since 13 February 2026 certain payments akin to interest may also qualify. Finance and Treasury Centre incentive conditions apply.
Secondary source used because no official page could be opened for this point.
A Qualifying Free Zone Person pays corporate tax at 0% on qualifying income and 9% on other taxable income, provided it keeps adequate substance, earns qualifying income, has not elected to be taxed at standard rates and meets transfer pricing requirements. Free zone persons only (mainland entities cannot use this regime). Failing any condition removes the status from the start of that tax period. The incentive period may be extended but cannot exceed 50 years. Detailed qualifying activities and de minimis rules are in Cabinet and Ministerial Decisions not reviewed here.
Reused from ae-tax-003.
Treasury and financing services to related parties or for the entity's own account, holding shares for investment purposes and headquarter services to related parties are listed as qualifying activities for a UAE Qualifying Free Zone Person. Free zone entities only; core income-generating activities must be performed in a free zone with adequate assets, staff and expenditure.
Secondary source; the Ministry of Finance site refused automated access.
A UAE Qualifying Free Zone Person meets the de minimis test only if its non-qualifying revenue does not exceed the lower of 5% of total revenue and AED 5 million. Certain revenue, such as revenue attributable to domestic or foreign permanent establishments and from some IP, is excluded from the calculation.
Secondary source; the Ministry of Finance site refused automated access.
A unit in an Indian International Financial Services Centre can claim a 100% exemption on specified income for 20 years, chosen at its option, out of 25 years. Central tax incentive for IFSC (GIFT City) units; income outside the holiday period is taxed at concessional rates. The section number under the Income-tax Act, 2025 was not confirmed.
Secondary source used because no official page could be opened for this point.
Loans and advances between a Global Treasury Centre in an Indian IFSC and other group entities of a listed foreign parent, located in notified jurisdictions, are excluded from deemed dividend treatment. Central tax rule; conditions on the parent and the counterparties' locations apply.
Secondary source used because no official page could be opened for this point.
Under section 207 of the Income-tax Act, 2025, dividends received by a foreign company are taxed at 20%, other than dividends from a unit in an International Financial Services Centre, which are taxed at 10%. Rate before any surcharge and health and education cess, which were not confirmed.
Surcharge and cess are not stated on this page. Reused from tx-withholding-and-treaties-003.
A licensed regional headquarters pays 0% income tax on income from eligible activities and 0% withholding tax on qualifying payments to non-residents for a renewable period of 30 years from the licence date. RHQ licensed by the Ministry of Investment that meets ZATCA's conditions and economic substance requirements; non-qualifying income is taxed at 20%.
The 16 February 2024 effective date of the RHQ tax rules comes from PwC Worldwide Tax Summaries (Significant developments). Reused from sa-tax-021.
A regional headquarters must start its mandatory activities within six months of its licence, start at least three optional activities within one year, and employ at least 15 full-time employees within one year. Regional headquarters registered with the Ministry of Investment.
Reused from sa-establish-019.
Under the Multinational Enterprise (Minimum Tax) Act 2024, Singapore applies an income inclusion rule and a domestic top-up tax at a 15% minimum effective rate for financial years starting on or after 1 January 2025, and has not adopted the undertaxed profits rule. Applies to in-scope multinational groups under the OECD GloBE rules; the revenue threshold was not confirmed on a Singapore source.
IRAS has a Pillar 2 Top-up Taxes section but its body text could not yet be checked automatically. Reused from sg-tax-013.
A domestic minimum top-up tax at 15% applies to multinational groups with consolidated revenue of EUR 750 million or more in at least two of the four preceding financial years, for financial years starting on or after 1 January 2025, under Cabinet Decision No. 142 of 2024. Large multinational groups only. The return and payment are due within 15 months after the financial year end (18 months for the transitional year).
Secondary source; the Cabinet Decision text could not yet be checked. The FTA published a Top-up Tax Scope and Registration guide (TTGREG1, August 2026) on its guides page, but the PDF could not be fetched, so registration deadlines and whether an income inclusion rule or undertaxed profits rule applies were not confirmed. Reused from ae-tax-006.
The Economic Development Board's incentives include the Refundable Investment Credit, the Pioneer Certificate Incentive, the Development and Expansion Incentive (which also covers headquarters activities), the Finance and Treasury Centre Incentive and the Intellectual Property Development Incentive. Tax incentives rest on the Economic Expansion Incentives Act and the Income Tax Act; award criteria and concessionary rates are set case by case and were not confirmed.
Reused from sg-regulatory-g08.
Questions on this topic
13 statements on treasury centres and incentives
