Is foreign-sourced income that is kept offshore (“foreign-sourced offshore income”) and used for payment of one-tier tax exempt dividends into the shareholder’s offshore bank account considered received in Singapore and subject to tax?
No. The foreign-sourced offshore income used by a company in this manner does not constitute income received in Singapore from outside Singapore and is therefore not taxable.
This is subject to the condition that the one-tier tax exempt dividend is paid directly into the shareholder’s offshore bank account and does not involve any physical remittance, transmission or bringing of funds into Singapore by the dividend paying company for the purpose of the dividend payment.
Source: Taxable and Non-taxable Income - IRAS
Singapore + offshore bank/EMI seems like a good option if you don't mind the cost of accounting and director services in Singapore.
In practice, has anyone had issues with claiming foreign sourced offshore income in Singapore?