Not-Ordinarily-Resident (NOR) scheme — final years — Step-by-step walkthrough
Raffles Corporate Services works with a panel of corporate and employment law firms; this article is general information, not legal advice.
The Not-Ordinarily-Resident (NOR) scheme gave qualifying expats time-apportionment of Singapore employment income and tax exemption on certain employer pension contributions. The scheme has been discontinued for new entrants, but final cohorts still enjoy benefits. This step-by-step walkthrough explains the legacy rules and what replaces them.
What the Not-Ordinarily-Resident scheme was
The Not-Ordinarily-Resident (NOR) scheme was a five-year concession for senior, mobile professionals who became Singapore tax-resident after a period of non-residence. Its headline benefit was time-apportionment of employment income: an NOR taxpayer who spent a qualifying number of days working outside Singapore could exclude the overseas portion of employment income from Singapore tax, subject to a minimum effective tax floor. A second benefit exempted certain non-mandatory employer contributions to overseas pension funds.
The scheme operated under the Income Tax Act 1947. For the residency tests that underpin any NOR analysis, see Section 13O vs Section 13U: Comparing Singapore’s Family Office Tax Incentive Schemes (2026); for the resident-versus-non-resident treatment that now governs most expats, Form C-S vs Form C-S (Lite) vs Form C: Which Singapore Tax Return Should Your Company File (2026) is the key companion.
This article is general information, not tax or legal advice; Little Big Employment Agency works with a panel of corporate and employment law firms.
Why the scheme is in its final years
The NOR scheme was discontinued for new applicants, with the last qualifying status granted for Year of Assessment 2020 and the final five-year periods accordingly running out by around Year of Assessment 2024. The concession and its conditions were administered under the Income Tax Act 1947. No new NOR status can be granted, so the scheme now matters mainly to taxpayers in their closing concession years and to advisers reconstructing past positions. Anyone still within a valid NOR period should ensure the remaining years are claimed correctly.
The two core NOR benefits explained
Time-apportionment of income required at least 90 days of business travel outside Singapore in the year and a minimum total Singapore employment income, with an effective tax rate floor of 10 per cent applying to total employment income so the benefit could not reduce tax below that floor. The pension-contribution exemption covered non-mandatory contributions made by the employer to a non-Singapore pension or provident fund, capped by reference to what would otherwise be CPF-equivalent limits.
Cost, timeline and step-by-step for remaining claims
Key anchors and sequence for any still-valid claim:
- Concession length: five consecutive Years of Assessment from the year status was granted.
- Minimum business-travel days for time-apportionment: 90 days outside Singapore.
- Minimum Singapore employment income condition: S$160,000.
- Effective tax rate floor: 10 per cent on total employment income.
Steps: (1) confirm the taxpayer holds valid NOR status and which years remain; (2) document overseas business-travel days; (3) compute the apportioned exemption and apply the 10 per cent floor; (4) claim in the relevant return; (5) retain travel and remuneration records. Our companion guide at Not-Ordinarily-Resident (NOR) scheme — final years — Complete 2026 guide sets out the apportionment computation in detail.
What replaces NOR for new expats
With no successor concession, new senior hires are taxed under the ordinary resident rules: progressive rates to 24 per cent with reliefs capped at S$80,000. Remuneration structuring now focuses on the standard rules rather than apportionment. Employer pension and CPF treatment follows the standard position, with CPF administered by the CPF Board for citizens and PRs only. The authoritative legacy guidance remains published by IRAS.
Common mistakes and gotchas
Errors include assuming NOR can still be applied for, miscounting overseas business-travel days, ignoring the 10 per cent effective-rate floor, and failing to keep contemporaneous travel records to support an apportionment claim. Advisers sometimes apply NOR benefits beyond the five-year window. Investment-regulation matters affecting relocating executives fall to Monetary Authority of Singapore; tax positions should be confirmed against IRAS guidance.
Reconstructing a valid NOR position for closing years
Because no new Not-Ordinarily-Resident status can be granted, the work now is precise rather than strategic: confirm that a taxpayer holds a valid status, identify exactly which of the five Years of Assessment remain open, and make sure each remaining year is claimed correctly. The status runs for five consecutive Years of Assessment from the year it was granted, so a taxpayer granted status for Year of Assessment 2020 would see the concession run through to around Year of Assessment 2024. Anyone advising on prior-year returns or amended assessments needs to map these dates carefully before applying any benefit.
Documentation is decisive for these legacy claims. The time-apportionment benefit depends on at least 90 days of business travel outside Singapore in the year, so contemporaneous travel records, boarding passes and itineraries are what support the claim if it is reviewed. Without them, an apportionment claim is difficult to sustain.
How time-apportionment and the 10 per cent floor interact
Time-apportionment excluded the portion of employment income attributable to days worked outside Singapore, but it was never unlimited. A floor applied so that the effective tax rate on total employment income could not fall below 10 per cent, and a minimum Singapore employment income condition of S$160,000 had to be met. In practice this meant a high-earning, frequently travelling executive could exclude a meaningful slice of income, but the floor capped the benefit so that the scheme remained a concession rather than a route to very low taxation. Computing the apportionment and then testing it against the floor is the essential two-step.
The pension-contribution exemption
The second NOR benefit exempted certain non-mandatory employer contributions to a non-Singapore pension or provident fund, recognising that mobile executives often retained home-country retirement arrangements. The exemption was capped by reference to limits analogous to CPF, and the employer had to forgo a corresponding deduction. For closing-year claims this benefit is less commonly in play than time-apportionment, but where an employer made qualifying contributions it should not be overlooked.
Worked example: a final-year NOR claim
Suppose an executive in the last year of a valid NOR period earns S$400,000 of Singapore employment income and spent 100 days on business travel outside Singapore. She meets the 90-day and S$160,000 conditions, so she can apportion out the overseas-work portion of her income. After apportionment, the system tests her effective rate against the 10 per cent floor on total employment income; if the apportioned result would drop her below 10 per cent, her tax is topped up to that floor. The net effect is a lower bill than ordinary resident treatment, but only within the floor, and only because the year remains within her five-year window.
Related guides and where to go next
NOR analysis rests on the residency tests and the ordinary resident rules that now govern new hires. For the residency foundation, Section 13O vs Section 13U: Comparing Singapore’s Family Office Tax Incentive Schemes (2026) is essential, and Form C-S vs Form C-S (Lite) vs Form C: Which Singapore Tax Return Should Your Company File (2026) covers the resident-versus-non-resident treatment that replaced the scheme in practice. Our deeper walkthrough at Not-Ordinarily-Resident (NOR) scheme — final years — Complete 2026 guide sets out the apportionment computation step by step.
FAQs
Can I still apply for NOR status? No. The scheme is closed to new applicants; the last status was granted for Year of Assessment 2020.
What did time-apportionment do? It excluded the overseas-work portion of employment income from Singapore tax, subject to a 10 per cent effective-rate floor and travel-day conditions.
How many business-travel days were required? At least 90 days of business travel outside Singapore in the year.
What replaces NOR? Nothing equivalent; new expats are taxed under the ordinary resident rules with standard reliefs.
Do any taxpayers still benefit? Only those within a valid five-year NOR period; confirm remaining years and conditions on IRAS.
Need help with this? Call, SMS or WhatsApp +65 8501 7133, or email [email protected]. Little Big Employment Agency (EA Licence 19C9790) works with a panel of corporate and employment law firms; this article is general information, not legal advice.