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Ratification Of The Agreement Between Singapore And Egypt For The Avoidance Of Double Taxation And The Prevention Of Fiscal Evasion With Respect To Taxes On Income

27 Jan 2004

An Agreement between the Government of the Republic of Singapore and the Government of the Arab Republic of Egypt for the Avoidance of Double Taxation and the Prevention of Fiscal Evasion with respect to Taxes on Income enters into force today following the completion of ratification process. Its provisions shall apply generally with effect from Year of Assessment 2006.

2 The Agreement aims to facilitate greater cross-flows of trade, investment, technical know-how and expertise between Singapore and Egypt so as to strengthen bilateral economic links for the benefit of both countries. Through the provisions of the Agreement, double taxation which may arise from the cross-border flows of income between the two countries will be eliminated. The taxing rights of each country on all forms of income are also specified in the Agreement.

3 The Agreement provides for the exemption or reduction of tax in the country of source on various types of income derived by residents of the other country, including the exemption from tax in the country of source on profits derived from the operations of ships or aircraft in international traffic.

4 To eliminate double taxation, Egypt will allow tax paid in Singapore as a credit against Egyptian tax on income arising in Singapore. In the case of dividends received from Singapore, the Singapore tax on that portion of the profits out of which the dividends are paid also qualifies for tax credit in Egypt if the Egyptian company owns at least 10% of the share capital of the Singapore company.

5 Singapore will also allow tax paid in Egypt as a credit against Singapore tax on income arising in Egypt under similar conditions. In addition, Singapore will grant tax sparing credit for Egyptian tax exempted or reduced in accordance with Egyptian tax laws relating to incentives for the promotion of economic development in Egypt. The provision of tax sparing will apply for the first ten years for which the Agreement is effective.

6 With the coming into force of this Agreement, Singapore now has in force Double Taxation Agreements with 47 countries. The full text of the Agreement is published in the Government Gazette today. The full text of the Agreement is also available on the Inland Revenue Authority of Singapore's (IRAS) website at