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Ministry of Finance (MOF)
Double Taxation Agreements

Singapore-Brazil Agreement for the Avoidance of Double Taxation Enters into Force

1 December 2021

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1. The Agreement between the Republic of Singapore and the Federative Republic of Brazil for the Elimination of Double Taxation with respect to Taxes on Income and the Prevention of Tax Evasion and Avoidance (“DTA”), signed on 7 May 2018, entered into force on 1 December 2021.

2. The DTA will benefit businesses in both Singapore and Brazil as well as boost bilateral trade and investment flows between the two countries. For more information on this DTA, please refer to our press release here issued on 7 May 2018. The full text of the DTA will be available here.

MINISTRY OF FINANCE
1 December 2021

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Annex: Summary of key terms in the Singapore-Brazil DTA

Article in the DTA

Key terms in the DTA

Article 5, Permanent Establishment

  • Threshold of six months for construction-related activities, beyond which residents of a contracting state could trigger a taxable presence in the other contracting state;

  • Threshold of 183 days in any twelve-month period for the furnishing of services by an enterprise of a contracting state within the other contracting state

Article 10, Dividends

  • 10% withholding tax rate (if shareholding ≥ 25% throughout a 365-day period)

  • 15% withholding tax rate (all other cases)

Article 11, Interest

  • 10% withholding tax rate (if the beneficial owner is a bank and the loan has been granted for at least five years for the financing of the purchase of equipment or of investment projects)

  • 15% withholding tax rate (all other cases)

Article 12, Royalties

  • 15% withholding tax rate (use or the right to use trademarks)

  • 10% withholding tax rate (all other cases)

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