Singapore-Russia Avoidance Of Double Taxation Agreement Ratified

Singapore's agreement with the Russian Federation for the avoidance of double taxation comes into force on 16 January 2009 following the completion of ratification formalities. The provisions of the Agreement shall apply to income derived on or after 1 January 2010.

2. The Agreement, which is Singapore's 60th agreement for the avoidance of double taxation, encourages and facilitates cross-border trade and investment between Singapore and Russia through the lowering of tax barriers and the better definition of taxing rights between the two nations. The main provisions under the Agreement include the following:

a) Lower withholding tax rates are imposed on dividends, interest and royalties. The tax rate for interest and royalties is 7.5% while the following rates apply to dividends:

i) 5% (for corporate shareholders holding at least 15% of the share capital and has invested at least US$100,000 or its equivalent in other currencies);
ii) 5% for the Government; and
iii) 10% (for other shareholders)

b) Tax credit would be available for residents earning foreign-sourced income. In the case of dividends received from Russia, Singapore also allows tax credit on the underlying tax paid for the dividends (i.e. tax credit on the corporate tax on the profits out of which the dividends are paid) if there is at least 10% shareholding.

c) A building site, a construction, installation or assembly project, or supervisory activities connected therewith constitute a permanent establishment only if it lasts more than 6 months. The period threshold for furnishing of services is more than 3 months in any 12-month period.

3. The full text of the DTA will be published in the Government Gazette on 16 January 2009, and will also be available on the Inland Revenue Authority of Singapore's (IRAS) website at www.iras.gov.sg.

MINISTRY OF FINANCE