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Appointment of an Agent under Section 33(1) of the GST Act to Act on Behalf of Overseas Business

Updated: May 5, 2023


Appointment of an Agent under Section 33(1) of the GST Act
Appointment of an Agent under Section 33(1) of the GST Act


As a section 33(1) agent, an agent will be held accountable for any tax due from the overseas business and obligated to discharge such duties as may be imposed on the overseas business.


What an Agent Needs to Do


  • Ensure that the overseas business file GST and pay tax on time.

  • Email Comptroller of Goods and Services Tax within 30 days should there be any changes in the mailing address to be used for correspondences regarding the overseas business.


Importing Goods on behalf of Overseas Persons as a Section 33(1) Agent


As a section 33(1) agent of a GST-registered overseas principal, you are responsible for the overseas principal's GST obligations, including GST accounting.


You should use the overseas principal's GST registration number to charge and calculate GST on taxable supplies made by the overseas principal.


For goods imported on behalf of an overseas principal, you will use your own Unique Entity Number (UEN) to import the goods. The "Importer" field on the import permit should show "(your name as the Section 33(1) agent) on behalf of (name of overseas principal)".


You must declare goods imported on behalf of a GST-registered overseas principal and the corresponding input tax claim on the overseas principal's GST return.


If you are under the Major Exporter Scheme, you cannot use your MES status to import goods on behalf of a GST-registered overseas principal. If an overseas client wants to join MES, he should apply for MES in his name. Once approved, you can use the overseas principal's MES status to import goods belonging to the overseas principal into Singapore. You will use your UEN to import goods. However, the "importer" field on the import permit should show "(your name as Section 33(1) agent) on behalf of (the overseas principal's name)". You cannot import your goods using an overseas principal's MES status.


If an overseas principal registered for GST cannot use your UEN to import goods into Singapore because the goods to be imported are controlled goods (such as military goods, strategically controlled goods, etc.) and you do not have the necessary authorization (advance notification), permit or certificate approval) from the relevant government agency to import such goods, the non-Section 33(1) agent importing the goods must obtain the necessary authorization from the relevant government agency.


The overseas principal must also maintain the following documents to prove that it has satisfied the GST input tax conditions:


  1. Agreement;

  2. Supplier invoice;

  3. Import license;

  4. Evidence of payment of import GST by a GST-registered overseas principal;

  5. Import transportation and shipping documents (such as packing list, bill of lading or airway bill, etc.);

  6. Appointment of a non-Section 33(1) agent as processing agent;

  7. Documents proving that the GST-registered overseas principal and you do not have a license; and

  8. A declaration letter from a non-Section 33(1) agent stating that it will not claim import GST on its GST return.


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