Country Business Reports Interviews And Articles By Discovery Reports

Natarajan & Swaminathan delivers quick, honest and efficient audit and advisory services

The firm leverages seven decades of expertise and a tech-driven approach to support Indian conglomerates eyeing Singapore’s market

Country Business Reports interviews and articles by Discovery Reports

Indian conglomerates and subsidiary firms in the software, financial, wealth and asset management sectors looking to establish a foothold in Singapore can rely on chartered accountants firm Natarajan & Swaminathan. Servicing the highest number of Indian companies in the Lion City, including Mustafa and the Modi Group of Companies, Natarajan & Swaminathan boasts seven decades of experience in the fields of advisory, assurance, financial due diligence, risk management, dispute resolution, tax and liquidation services. Today, the firm also works with associate and affiliate companies to provide business consulting, global tax advisory, back office processing, human resource, incorporation and immigration-related services.

“We get clients mostly through references,” said Rangarajan Narayanamohan, managing partner. “Our existing clients go back and recommend new clients to us. In our industry, time is of the essence, so we provide fast services, and we constantly update our offerings to deliver complete and satisfactory assistance to clients.”

Natarajan & Swaminathan seeks to bolster its connections with similar advisory firms worldwide that wish to penetrate the Singapore market. The firm welcomes more affiliate partners in Hong Kong, Malaysia, Dubai and Britain who are in need of professional or business consultancy services, and who can provide references.

“We never think of anyone as our competitor,” Narayanamohan said. “We just focus on whatever job we get and execute it on time and professionally. Whether the client is big or small, we are responsible and accountable to deliver the client’s requirements quickly and efficiently.”

Global Minimum Tax

The Organization for Economic Co-operation and Development (OECD) and the Group of 20 (G-20) countries agreed to an overhaul of the international tax system, which will include a 15 per cent global minimum corporate tax on multinationals with annual revenue above €750 million (S$1.15 billion) which is going to take effect from 2023.

The tax reform also requires 25 per cent of profits from companies with €20 billion or more global annual turnover to be reallocated to jurisdictions where their customers are located. So far, 141 tax jurisdictions have agreed to implement the reform, which is designed to discourage multinationals from shifting profits to low-tax jurisdictions.

Asia has 48 countries and atleast 51 tax jurisdictions if Hong Kong, Macau and Taiwan are included. Four of these are members of the OECD and six in the G-20. However, developing economies need not only more tax revenues to finance their budgets but also the flexibility to provide tax incentives to multinationals to attract investment that can generate employment and other economic benefits.

Policy makers may need to weigh the different considerations & design the tax policy to achieve a good balance across these competing norms. The global minimum tax rate & other provisions in the reforms are also aimed at putting an end to decades of tax competition between governments to attract foreign investment. Careful thought needs to be given to the impact on tax incentives in areas such as environment & climate change. OECD needs to ensure in particular that the global tax reforms do not remove the incentives needed to encourage research & development of emerging innovative technologies for the green economy.

Under BEPS (Base Erosion and Project Shifting), multinational enterprises (MNEs) with a global turnover in excess of 750 million euros (S$1.15 billion) that operate in jurisdictions that are subject to an effective corporate tax rate of less than 15 per cent will have to top up the taxes paid in those jurisdictions in their “home” jurisdiction. The top-up will be based on the difference between the corporate minimum tax of 15 per cent and the effective tax rate levied in that other jurisdiction.

When international tax rules are changed, the government will consider making changes to our corporate tax system accordingly, in consultation with businesses & tax professionals.

There are around 1,800 such MNEs in Singapore, and many pay effective tax rates of well below 15 per cent because of various tax incentives.

The corporate tax rates of some of neighboring countries are stated below for information:









Hong Kong










Excerpts from Minister Lawrence Wong’s speech on the budget on 18th February, 2022 are as follows:

There are two pillars in BEPS 2.0. The first reallocates profit of the largest and most profitable multi-national enterprises (MNEs), from where activities are conducted to where consumers are located.

“There are ongoing international discussions on how to determine the jurisdictions which will surrender profits for reallocation to the markets under Pillar 1 & how much each will surrender.  Given our small domestic market & the extent of activities conducted here by MNEs, Singapore will lose tax revenue under Pillar 1.”

The second pillar introduces the 15 per cent global minimum effective tax rate for MNE groups with annual global revenues of €750 million (S$1.1 billion) or more, under its Global Anti-Base Erosion (GLoBE) Model Rules, among other things.

“What this means is that if such an MNE were to have an effective tax rate of less than 15 per cent in Singapore at the group level, other jurisdictions such as its home jurisdiction can collect the difference up to 15 per cent.”

Singapore will adjust its tax System in response to Pillar 2 GloBE rules. It is exploring a top-up tax called the Minimum Effective Tax Rate, or METR which will top up the MNE groups’ effective tax rate in Singapore to 15 per cent.

The METR will apply to MNE groups operating in Singapore that have annual revenues of at least €750 million as reflected in the consolidated financial statements of the ultimate parent entity.

The Inland Revenue Authority of Singapore will study the tax rate further & consult industry stakeholders.

For further information please reach out to:

Mr. Rangarajan Narayanamohan,
FCA Senior Partner Natarajan & Swaminathan, Chartered Accountants, Singapore
Contact number: (65) 9832 3722
Address: 1 North Bridge Rd, #19-04, High Street Centre, Singapore 179094

 Singapore Private Family Trust

 Singapore Private Family Trust

Singapore Private Trust Company (“PTC”) can be used as a private investment structure by business families/ ultra-high net worth individuals (“Settlor” or “Sponsor”) for managing family wealth. PTC is a private corporate entity established in Singapore solely for the purpose of acting as trustee in relation to a specific trust or trusts for a single family.

The PTC structure will also help the Sponsor to retain ownership and control over the family assets instead of transferring it to an independent Trustee (as is required in a traditional trust arrangement). The operational efficiency of the family trust can be achieved by putting in place at the board level certain processes for its day-to-day operations and running it like a professional organisation.

The shareholding and directorships in the PTC can be structured to create control over the trust assets in a manner desired by the Sponsor. Only the beneficiaries (which can be same or different class of people but must be related to the Settlor) are entitled to the distributions of the Trust Funds (except that the beneficiary of the residual estate of the Settlor may be a charity).

Singapore PTC
PTC bears the features of a company (such as corporate management and limited liability) and yet, is the trustee for specific family trusts

  • Acts as “dedicated’ trustee for a specific trust or a few trusts.
  • Must have at least one director who is “ordinary resident” in Singapore

Benefits in general

  • Settlor can formulate the succession to board
  • Decisions can be taken in a faster manner
  • Can maintain more control and influence over the management of the family assets.
  • Flexibility in structuring and yet maintain governance and discipline in a corporatized manner.
  • Handhold and coach younger members of the family on the broader management of family wealth.
  • Puts total control over management of assets in hands of competent persons identified by the Settlor.
  • PTC being a legal entity can be perpetually; passing to subsequent generations.


  • A board of directors and if required, sub committees.
  • Usually consist of the Settlor, independent experts, Family members and trust advisers.
  • Composition of the Board can be changed at any time to keep up with changes in the family circumstances.
  • Can inculcate discipline and transparency in the management of family wealth in a well-documented manner by adopting high standards of corporate governance.

Assets of the trust will be held in the name of the PTC as the legal owner and for the benefit of the beneficiaries.

The usual legal documents include the Constitution of the PTC, Trust Deed, appointment letters of directors and professional parties who provide specific service to the private family trust.

In Singapore, PTCs are exempted from seeking trust licensing, but are required to mandatorily appoint a trust administrator to perform due diligence checks to ensure compliance with anti-money laundering regulations. A suitable process must be put in place to conduct day to day operations of the family trust.

If the PTC is structured suitably and meets with certain requirements, it may qualify for exemption from taxation in Singapore. Having economic substance in Singapore and value add to Singaporean economy is one of aspects which are relevant for the above.



  • Fund administration and custody done by bank.
  • Minimum wealth for service around S$15 million
  • DBS serves as banker to more than a third of the 700 single family offices established in Singapore.
  • Clients also enjoy cost savings through shared resources and expenses across multiple sub-funds.
  • VCC does away with the use of companies or trusts, which were the traditional vehicles used by wealthy families in wealth structing.
  • DBS MFO is also an attractive option for some families who are not looking to immediately locate to Singapore.

Professional Services for FATCA & CRS Compliance

Professional Services for FATCA & CRS Compliance

We can assist professionally to do the registrations of FATCA & CRS with relevant government authorities and carry out the annual return filing compliance for your company. 

A brief information about both the compliances are as follows-


The Foreign Account Tax Compliance Act (FATCA) was enacted by the US to target non-compliance with the US tax laws by US persons using non-US accounts

FATCA is a US law which requires all Financial Institutions outside of US, also known as Foreign Financial Institutions (FFIs), to regularly submit information on financial accounts held by US persons to the US tax authorities.  The US intent of FATCA is to deter and detect US tax evasion through the use of Foreign Financial Accounts.  The reporting obligations under FATCA covers any non-US entities like banks and other financial institutions including individuals and Portfolio Management Companies.

If you run a Variable Capital Company or an Investment Holding Family Office, you are required to do FATCA and CRS registrations for compliance.

The Singapore Financial Institutions will need to perform due diligence checks to identify Financial Accounts held by US persons (as defined) and to report to IRAS Singapore, as the Singapore government has entered into an intergovernmental agreement to collect information for submission to US tax authorities.  Initial registration of FATCA has to be done directly with US tax authorities and for Singapore tax resident companies, they can submit annual returns to the Singapore Tax Authorities for compliance.  (Singapore has signed with US for Model 1 Intergovernmental Agreement for compliance) as mentioned earlier.



CRS is the internationally agreed standard endorsed by the Organization of Economic Cooperation and Development (OECD) for the exchange of financial account information. It is the new information-gathering and reporting requirement for Financial Institutions in participating countries/jurisdictions, to help fight against tax evasion and protect the integrity of tax systems.  It has been designed to prevent offshore tax evasion. All foreign investments handled by a Financial Institution becomes a subject to a CRS report.

The CRS required financial Institutions in a jurisdiction to report to their tax administration the financial accounts held by non-resident individuals and entities or certain entities controlled by non-resident individuals.


If you are a tax resident in a country with which Singapore has signed a Competent Authority Agreement, we will have to disclose your account information to the Inland Authority of Singapore. A person is only reported under the CRS regulations when they are identified as being tax resident in a Reportable Country and hold Financial Assets of their country which includes the following-

  • Depository Account
  • Custodial Account
  • Equity or Debt interest in Investment entities.
  • Cash Value Insurance Contract
  • Annuity Contract

It covers accounts held by individuals and entities, including businesses, trusts and foundations.  Not just banks, but broker-dealers, investment funds and insurance companies are also required to report.

Financial Accounts that are subject to review and possible review are –

  • Bank accounts
  • Holdings in mutual funds and similar investments
  • Brokerage and custodial accounts
  • Annuity contracts (including segregated fund contracts)
  • Life Insurance Policies and cash value