Orbitax Tax News & Alerts
Singapore's Tax news & updates from Orbitax and partners
Singapore Tax News
Indian decision on the attribution of profits to dependent agent permanent establishment
Treaty between Singapore and China (People's Rep.) signed
Ruling that subscription fees for commercial portal taxable in India
New case law on Japan-Singapore tax treaty and Japanese CFC provisions
Budget 2007 – details
Planned corporate tax cut
Treaty between Singapore and Germany enters into force
New treaty between Belgium and Singapore – details
Protocol to treaty between Singapore and New Zealand enters into force
Protocol to treaty between New Zealand and Singapore approved
ATO to allow refunds of royalty withholding tax
Indian decision that fees for (interior) designs or drawings do not constitute technical service fees or royalty under India-Singapore tax treaty
Treaty between Singapore and Malta signed
Treaty between India and Singapore – Singapore seeks further amendments re CGT
The new income tax treaty and protocol between Singapore and Malaysia, signed on 5 October 2004, entered into force on 13 February 2006. In Singapore, the treaty will generally apply from 1 January 2007. In Malaysia, the treaty will apply in respect of petroleum income tax to income derived on or after 1 January 2008 and in respect other tax from 1 January 2007. From these dates, the new treaty generally replaces the Singapore and Malaysia income tax treaty of 26 December 1968.
French Court of Appeals decision on debt waivers granted to branches of foreign subsidiary by French parent company published
The Singapore Ministry of Finance has announced that following the completion of ratification formalities, the new income tax treaty between Singapore and Israel, signed on 19 May 2005, will enter into force as of 6 December 2005. The new treaty generally applies from 1 January 2006. From this date, the new treaty generally replaces the Singapore-Isreal income tax treaty of 27 September 1971.
In McDermott Industries (Aust) Pty Ltd v. FCT, the taxpayer company argued that it was not required to withhold tax on bare boat charter payments that it made to a Singaporean company (S-Co). Australia's Federal Commissioner of Taxation sought to apply a rule that a deduction for a royalty subject to withholding tax is not available to the paying company, unless it has paid the withholding tax (in which case the deduction becomes available in the year in which the royalty was incurred). The taxpayer's position was that royalty withholding tax was not payable because S-Co had a deemed permanent establishment under the tax treaty between Australia and Singapore to which the royalties related.
China (People's Rep.) and Mexico signed a first-time tax treaty on 12 September 2005. Further details of the treaty will be reported subsequently.
New Zealand and Singapore signed a protocol to the New Zealand-Singapore treaty of 21 August 1973 on 5 September 2005. Further details of the protocol will be reported subsequently.
India and Singapore signed a protocol dated 29 June 2005. This protocol will form part of the India-Singapore tax treaty dated 24 January 1994, and will enter into force and be effective as from 1 August 2005.
A new income tax treaty and protocol between Singapore and Israel was signed on 19 May 2005
Malaysia and Singapore signed a new income tax treaty and protocol on 5 October 2004.
Israel and Singapore signed a new tax treaty on 19 May 2005. Once in force, it will replace the Singapore-Israel income tax treaty of 27 September 1971.
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