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Ratification of Supplementary Agreement Amending the Convention Between Singapore and Belgium for the Avoidance Of Double Taxation and Prevention of Fiscal Evasion With Respect To Taxes On Income

04 May 2004

A Supplementary Agreement, which was signed on 10 December 1996 between the Government of the Republic of Singapore and the Government of the Kingdom of Belgium to amend certain Articles of the Convention for the Avoidance of Double Taxation and the Prevention of Fiscal Evasion with respect to Taxes on Income signed on 8 February 1972, enters into force on 5 May 2004 following the completion of ratification formalities. The provisions of the Supplementary Agreement will have effect for Years of Assessment 1998 and after.

2. Changes in economic circumstances and policies had made it necessary to review some of the Articles of the Convention for the Avoidance of Double Taxation and the Prevention of Fiscal Evasion with respect to Taxes on Income between the Government of the Republic of Singapore and the Government of the Kingdom of Belgium signed on 8 February 1972.

3. Under the Convention, the rate of withholding tax on interest is reduced to not more than 15% and industrial royalties are exempt from tax in the country where they arise. Where interest and royalties are exempt from tax in Singapore, Belgium will give a tax credit of 15% of the gross amount of such interest or royalties. The Supplementary Agreement further reduces the rate of withholding tax on interest to not more than 10% and provides for a rate of withholding tax of 5% for all types of royalties. Where interest or royalties are exempt from tax in Singapore due to tax incentives granted in connection with industrial or commercial development projects, Belgium will give a tax credit of 10% of the gross amount of such interest and 5% of the gross amount of such royalties.

MINISTRY OF FINANCE