Raffles Consulting Services

GST zero rating for exported goods and the 60-day evidence file

GST zero rating for exported goods depends on the export arrangement, time of supply and complete matching evidence collected within 60 days.

GST zero rating for exported goods is available only when the supply fits the export rules and the business keeps the required matching evidence. The 60-day period generally runs from the time of supply, which is the earlier of invoicing and payment. If the goods or documents do not meet the conditions in time, the supplier must standard-rate the sale at 9 per cent unless a specific exception applies.

Classify the export arrangement before issuing the invoice. Direct exports, indirect exports, postal or courier shipments and hand-carried goods have different evidence requirements.

Determine the time of supply

The current IRAS exporting goods page states that the time of supply for exports is the earlier of invoice issuance and receipt of payment. Record that date in the export evidence tracker.

For this reason, a pro forma document may not have the same GST effect as a tax invoice, but the actual documents and payment timing must be reviewed. Do not restart the 60-day count because the shipment was delayed or because a final invoice was issued later.

Link the time of supply to the expected export date. If the commercial schedule cannot meet the evidence period, decide whether to charge GST first and correct the treatment only through a permitted process after the facts are complete.

Classify direct and indirect exports

A direct export generally occurs when the supplier has custody of the goods and controls the export arrangement. Examples include using the supplier’s freight forwarder, courier or handling agent. Keep the commercial and transport documents required for the scenario.

In practice, an indirect export occurs when the supplier lacks custody or control over the export arrangement. The default treatment is a local standard-rated supply. A zero-rated exception may apply when the supplier is certain at the time of supply that all goods will be exported and obtains the required evidence within 60 days.

Write down who appoints the freight forwarder, who delivers the goods, where custody passes and who appears as exporter or sender on the transport record. Contract wording should agree with the actual logistics.

Build a matching evidence chain

The IRAS GST Guide on Exports sets out scenario-specific records. A typical file can include the customer’s purchase order, sales invoice, delivery or packing record, insurance document, proof of payment, export permit and transport evidence such as an air waybill, bill of lading or freight-forwarder shipment record.

At the same time, the documents must describe the same goods, quantities, customer, destination and dates. Create a reconciliation field for invoice number, permit number, shipment number and payment reference. Investigate split shipments, short deliveries, substitutions and returns rather than filing unmatched PDFs.

If an export document is lost, IRAS says the supplier should obtain a duplicate from the issuer marked for GST purposes, dated and authenticated. Record why the replacement was needed and who checked it.

Tracker field Source Exception to resolve
Time of supply Invoice and payment records Different invoice or receipt dates
Export route Contract and freight instruction Customer controls the shipment
Goods and quantity Invoice, packing list and permit Substitution, split or short shipment
Destination and delivery Transport and tracking evidence No proof goods left Singapore
60-day status Dated checklist Missing export or document evidence

Handle postal and courier exports carefully

For shipments through a Singapore postal or courier company, keep the specific transaction and transport evidence required by the current guide. Shipment labels may be accepted in the relevant scenario, while proof of overseas delivery can be required. Download online tracking before the carrier removes it from public access.

As a result, Make sure the transport document names the Singapore supplier as exporter or sender where the scenario requires it and describes the goods. A tracking number alone may not connect the parcel to the invoice.

For regular small parcels, automate a weekly exception report. It should list invoiced zero-rated sales with no matched despatch, delivery or payment evidence and show the number of days remaining.

Assign each open exception to a named finance or logistics owner. The tracker should show the last follow-up, the missing document, the party expected to provide it and the planned accounting treatment if it does not arrive. Escalate unresolved items early enough to correct the GST return rather than discovering them after filing.

Use the correct route for hand-carried goods

For example, IRAS states that a GST-registered business that wants to zero-rate goods hand-carried through Changi Airport must use the Hand-Carried Exports Scheme unless it has written approval for an exemption. Hand-carried exports through other routes follow the relevant export guide.

Do not treat a customer’s travel itinerary as export proof. Check the scheme registration, endorsed permit or digital clearance and the full supporting document list. Train sales staff to recognise hand-carried requests before GST treatment is promised.

Correct a failed evidence file

If the required export and documentary evidence is not obtained within the allowed period, standard-rate the supply and account for GST. Record the accounting entry, return period, customer communication and whether any later adjustment is permitted under current guidance.

In addition, the IRAS GST audit focus page gives an example where zero-rated supplies were standard-rated because proper export evidence was unavailable. The audit risk is not solved by an overseas customer address on the invoice.

The Singapore tax compliance guide is the pillar cornerstone. The GST InvoiceNow reconciliation guide covers return differences, while the GST disclosure guide covers past errors. The Corporate and International Tax Consulting hub connects related guidance.

The safest zero-rating decision is made before dispatch. When the route, invoice, permit, transport record and payment can be matched within 60 days, the business can support the 0 per cent treatment without reconstructing the shipment during an audit.