Zero Rating and the (Un)Certainty of Conditions Imposed to Qualify for Relief

Abstract

In this article, the author discusses the related decisions of the Singapore GST Board of Review and the Singapore High Court, both of which allowed the zero rating treatment of the exports of goods even though the taxpayer did not fully satisfy the export documentation guidelines prescribed by the tax authority for zero rating relief. The courts ruled that the tax authority has to take the necessary steps to determine whether the goods were exported and the taxpayer was entitled to rely on the specific directions that were previously issued to the taxpayer for the zero rating treatment to apply even though the specific directions differed from the guidelines.