Tax Treaties (Double Taxation Agreements)

Singapore's Avoidance of double taxation agreements (DTAs)

DTAs help to promote bilateral investment and trade flows. Through the provisions of a DTA, taxpayers engaged in cross-border business can enjoy certainty on the taxing rights of either jurisdiction, benefit from the elimination of double taxation, and gain access to a platform to settle tax disputes.|

Currently, Singapore has more than 80 comprehensive DTAs in force. The full list of Singapore’s DTAs can be found on IRAS’ website.

Frequently Asked Questions (FAQs) on DTAs

 
  1. What is a DTA?

    A DTA is a bilateral agreement which provides clarity on the taxing rights of each contracting jurisdiction on all forms of bilateral income flows. The DTA also eliminates instances of double taxation which can arise from cross-border trade and investment activities. Usually, there would be provisions in the DTA for reduction or exemption of tax at source on certain types of cross-border incomes such as interest and royalties.
  2. How are DTAs negotiated?

    As with any other bilateral treaty, there would have to be mutual interest from both jurisdictions before formal negotiations can be established. While it is expected for each jurisdiction to push for terms that best serve its interests, compromises would have to be made to achieve an overall balance of benefits. Both sides may require more than one round of face-to-face meetings to resolve all outstanding issues and finalise the terms of the DTA.

    Upon the conclusion of negotiations, both jurisdictions would arrange for the DTA to be signed by the relevant authorities. Following the signing, both jurisdiction would have to ratify the DTA before it enters into force.
  3. How do I seek assistance if I encounter a problem relating to the application of a particular DTA?

    The Mutual Agreement Procedure (MAP) Article of a DTA sets out the process to resolve issues relating to the application of the DTA.

    Taxpayers who wish to take up their issues under the MAP should approach the tax authority of the State in which they are a tax resident.

    More information on the MAP can be found on IRAS’ website.

  4. What is the Multilateral convention to Implement Tax Treaty Related Measures to Prevent Base Erosion and Profit Shifting (“MLI”)?

    The MLI allows jurisdictions to swiftly amend their DTAs to implement the tax treaty-related Base Erosion and Profit Shifting (BEPS) recommendations. The MLI also improves the dispute resolution mechanisms in DTAs.
     
    In line with Singapore's commitment to implement the internationally-agreed standard on preventing treaty abuse, Singapore ratified the MLI on 21 December 2018. The MLI entered into force for Singapore on 1 April 2019.
     
    More information on the MLI can be found on IRAS’ website.