Where Singapore usually sits in a group
Singapore is rarely the first entity a group forms. It appears when a founder wants a regional holding company, when investors ask for a neutral jurisdiction, or when Asian customers want to contract with a local company. Each of those reasons produces a different tax profile, and the profile decides whether the Singapore company is genuinely resident and treaty-eligible.
Tax residency in Singapore follows where control and management are exercised, not where the company is registered. Directors who all meet elsewhere will struggle to support a residency claim, and without residency the treaty relief that motivated the structure disappears.