🇸🇬 Singapore vs 🇺🇸 United States (Delaware)
A side-by-side look at setting up a company in Singapore (Private Limited Company) and United States (Delaware) (Delaware C-Corp / LLC), plus 5 regulatory differences to plan for if you operate in both.
| Criterion | Singapore | United States (Delaware) |
|---|---|---|
| Typical vehicle | Private Limited Company | Delaware C-Corp / LLC |
| Foreign ownership | 100% | 100% |
| Minimum capital | SGD 1 | None |
| Time to incorporate | 1–5 days | 1–5 days |
| Corporate tax | 17% (partial exemptions) | 21% federal + state |
| VAT / GST | 9% | State sales tax |
| Dividend withholding | 0% | 30% (treaty relief) |
| Resident director | Required | Not required |
| Physical office | Virtual accepted | Virtual accepted |
| Annual running cost | USD 3,000–8,000 | USD 2,000–7,000 |
| Audit | Threshold-based | Not mandatory |
| Legal system | Common law | Common law |
| Currency controls | None | None |
Operating in both: key conflicts
Sanctions & export control: Extraterritorial sanctions reach differs
The higher-exposure jurisdiction applies its sanctions and export-control rules extraterritorially to group entities, personnel and USD/GBP clearing. Screen counterparties against the stricter list group-wide.
Employment: Termination regimes conflict
Notice periods and end-of-service entitlements differ; localise the termination and severance clauses.
Economic substance: Substance requirements apply on one side only
Directors, decision-making and core income-generating activity must be demonstrably located in the jurisdiction that imposes the substance test. Shared board meetings held elsewhere will fail the test.
Information exchange: Reporting frameworks are not symmetric
Account and entity classification differ between the two regimes; self-certification forms must be prepared separately.
Governance: Resident director requirements differ
One jurisdiction requires a resident director. Appointing the same individual in both can undermine the substance position of the other entity.
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Figures are indicative and change often. Not legal or tax advice — confirm with qualified counsel.