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Singapore-Australia-France-New Zealand-United Kingdom

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Singapore Amendment Orders on Effect of BEPS MLI to MAP Articles of Tax Treaties with Australia, France, New Zealand, and the UK

Singapore has published in the Official Gazette amendment orders made 28 May 2019 regarding the effect of the BEPS MLI in relation to the Mutual Agreement Procedure (MAP) Articles of the tax treaties with Australia, France, New Zealand, and the United Kingdom. The order in relation to the following amendments

  • For the tax treaties with Australia and the United Kingdom, the amendments providing that MAP cases must be submitted within three years from the first notification of the action resulting in taxation not in accordance with the provisions of the treaties;
  • For the tax treaty with France, the amendment providing that the competent authorities of the Contracting States shall endeavor to resolve by mutual agreement any difficulties or doubts arising as to the interpretation or application of the treaty; and
  • For the tax treaty with New Zealand, the amendment providing that the competent authorities may also consult together for the elimination of double taxation in cases not provided for in the treaty.

The amendment orders include that the MAP Article amendments have effect for a case presented on or after 1 April 2019, without regard to the basis period to which the case relates, except for cases that were not eligible to be presented immediately before 1 April 2019.

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