The Inland Revenue Authority of Singapore (IRAS) has published the impact of the Multilateral Convention to Implement Tax Treaty Related Measures to Prevent Base Erosion and Profit Shifting (MLI) for 14 of Singapore's tax treaties. Rather than including the MLI impacts directly within the text of the treaties as some countries have done (so-called synthesized texts), the impacts are provided in a new Annex to each of the treaties. The treaties are as follows:
For all of the treaties, the impacts laid out in the respective annexes have effect in Singapore:
Certain tax treaties are also impacted by the MLI arbitration provisions, which for Singapore apply with respect to any tax paid, deemed paid or liable to be paid, before, on, or after 1 April 2019. These include the treaties with Australia, Austria, France, Japan, Malta, New Zealand, Slovenia, and the United Kingdom.
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