Double Tax Agreement between Singapore and Panama came into force on 19 December 2011


 

 

Dear Valued Clients and Friends

Singapore has now 68 Double Taxation Agreement (“DTA“) with the rest of the world after the DTA with Panama came into force on 19 December 2011.  This DTA includes the internationally agreed Standard for the exchange of information for tax purposes upon request.  Other salient features of this DTA include the following:

Article 5 – Permanent Establishment (“PE”)

  • A building site, a construction, assembly or installation project, or supervisory activities in connection therewith will be deemed to be PE if they last for more than 9 months
  • The furnishing of services, including consultancy services, by an enterprise of a Contracting State through employees or other personnel engaged by the enterprise for such purpose will be deemed to be PE  such activities continue within the other Contracting State for a period or periods aggregating more than 270 days in any 12-month period.
Article 8 – Shipping and Air Transport
  • Profits derived by an enterprise of a Contracting State from the operation of ships or aircraft in international traffic is taxable only in that State.
  • Scope of income under this article includes the following:
    • Interest on funds connected with the operations of ships or aircraft in international traffic
    • profits from bareboat charter
    • Profits from the use, maintenance or rental of containers if they are incidental to operation of ships or aircraft in international traffic.
Article 10 – Dividends
  • 4% Withholding tax (if shareholder is the beneficial owner holding directly at least 10% of capital of the dividend paying company).
  • 5% withholding for all other cases

 

Article 11 – Interest

  • Maximum withholding tax rate of 5%

Article 12 – Royalties 

  • Maximum withholding tax rate of 5%

We trust that the above information is useful to you.

As always, we are pleased to assist you or your company in resolving any potential tax issues.  Please contact us at jack.wong@whm-consulting.com if you would like to discuss any of your/ your company’s concern on tax issues.

Best regards
Jack HM Wong
Founder and Lead Business & Tax Advisor
WHM Consulting Pte Ltd
E-mail: jack.wong@whm-consulting.com

Advertisements

Leave a Reply

Please log in using one of these methods to post your comment:

WordPress.com Logo

You are commenting using your WordPress.com account. Log Out / Change )

Twitter picture

You are commenting using your Twitter account. Log Out / Change )

Facebook photo

You are commenting using your Facebook account. Log Out / Change )

Google+ photo

You are commenting using your Google+ account. Log Out / Change )

Connecting to %s