Inland Revenue - Tax policy Tax Policy

News and information about the Government's tax policy work programme, including:
- proposed changes to the laws that Inland Revenue is responsible for
- updates on the progress of bills through Parliament
- policy announcements

Singapore

2009 agreement

Status: In force
Signed: 21 August 2009
In force: 12 August 2010
Effective:

In New Zealand: For withholding taxes from 1 October 2010; for other provisions, generally for income years beginning 1 April 2011.
In Singapore: Refer to frequently asked question below.
Refer to Article 25 of the agreement.

Legislation: Double Tax Agreements (Singapore) Order 2010
National interest analysis: PDF (92KB)

1973 agreement

Status: Terminated
Signed: 21 August 1973
Legislation: Double Taxation Relief (Singapore) Order 1973 (New Zealand Legislation website)

Protocol to the 1973 agreement

Status: Terminated
Signed: 21 August 1973
Legislation: Double Taxation Relief (Singapore) Order 1973 (New Zealand Legislation website)

Second Protocol to the 1973 agreement

Status: Terminated
Signed: 1 July 1993
Legislation: Double Taxation Relief (Singapore) Order 1973, Amendment No. 1

Third protocol to the 1973 agreement

Status: Terminated
Signed: 5 September 2005
Legislation: Double Taxation Relief (Singapore) Amendment Order 2006 (New Zealand Legislation website)

Frequently asked question

Dates of application

Question:

What is the date of application for the double tax agreement (DTA) for Singapore?

Answer:

The DTA entered into force on 12 August 2010. According to the entry into force formulation at paragraph 1(b) of Article 25 of the DTA, the provisions of the DTA will therefore apply in Singapore in respect of tax chargeable for any year of assessment beginning on or after 1 January 2012 (that is, year of assessment 2012, and later years of assessment).

However, understanding what this means in practice requires an understanding of how tax is imposed in Singapore.

The following links to the website of the Inland Revenue Authority of Singapore [Individuals: http://www.iras.gov.sg/irasHome/page.aspx?id=1526; Companies: http://www.iras.gov.sg/irasHome/page04.aspx?id=1392] clarify that, in Singapore, income tax is assessed on a preceding year basis.

This suggests that the provisions of the DTA will apply in Singapore to income earned during calendar years beginning on or after 1 January 2011 (or, for companies with a financial year that does not coincide with the calendar year, during any financial year ending in 2011) and thereafter. For withholding tax rates on dividends, interest and royalties, New Zealand Inland Revenue understands that the provisions of the DTA will apply in Singapore to income earned from 1 January 2011.

As New Zealand Inland Revenue cannot provide advice on the tax systems of other jurisdictions, any questions on this matter should be referred to the Inland Revenue Authority of Singapore.

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