<p>   The purpose of DTA is to familiarize all taxpayers with the interpretation and application of Singapore tax treaties, and also to clarify the mutually agreeing procedure in more detail.</p><p>   The manual states that the tax rules in most cases are different in each jurisdiction. Some aspects of taxation are universal and similar in different tax systems, while others have significant differences. For example, the difference is observed in the definitions of income, tax residency, tax base, as well as in tax rates and in the rules of taxation of non-residents. In addition, in the document the tax service of Singapore explained how double taxation can arise and what it leads to in economic and legal terms, as well as what functions are performed by tax treaties.</p><p>   Particular attention is paid to the Multilateral Convention on the implementation of measures in relation to tax treaties in order to counteract the dilution of the tax base and the movement of profits from taxation (BEPS), to which Singapore joined in June 2017. It is noted that not all Singapore tax treaties will be changed under the Multilateral Convention, since not all Singapore tax treaty partners plan to accede to the Multilateral Convention of BEPS, and not all those who have already joined it share the same approach to its implementation, as well as Singapore.</p><p>For those treaties that will nevertheless be modified under the Multilateral Convention, the main amendments will be the following:</p><ul><li>the inclusion of the preamble that the tax treaty is designed to eliminate double taxation but is not intended to create opportunities for non-taxation or tax reduction by way of avoiding or avoiding taxation;</li><li>inclusion of the "main objectives", in accordance with which the benefits provided for by the tax treaty will not be granted in cases where the main or one of the main objectives of any transaction is to receive tax benefits under the contract;</li><li>inclusion of certain provisions of the treaty, which allows taxpayers to request the holding of the mutual agreement procedure, if the competent authorities have not reached a consensus on a certain date.</li></ul><p>  Further, the guide explains the main provisions of tax treaties and emphasizes that, in addition to guidance, taxpayers should always directly address the text of the tax treaty, the provisions of which they plan to use. In addition, the guide explains in detail the mutually agreed procedure that is carried out when the tax authorities of two or more countries hold different positions regarding the application of the provisions of the tax treaty, which can cause double taxation.</p><p> </p><p class="justifyleft">   Full text of DTA can be found <span lang="EN-US"><span face="Calibri" size="3"><strong><a href="https://www.iras.gov.sg/irashome/uploadedFiles/IRASHome/e-Tax_Guides/etaxguide_Income%20Tax_Avoidance%20of%20Double%20Taxation%20Agreements%20(DTAs).pdf">here</a>.</strong></span></span></p><p> </p><p>   One of the latest agreements to avoid double taxation in Singapore is the agreement with Nigeria, signed on August 2, 2017. This document explains the tax rights of both jurisdictions to all forms of income that arise as a result of cross-border business activities. For example, profits from entrepreneurial activities, in accordance with the provisions of the concluded agreement, are taxable only in the jurisdiction of their registration, provided that the activity has not been conducted in another country through a permanent establishment. Otherwise, profits are taxed in another jurisdiction, but only a part related to a permanent establishment. A permanent establishment is an office, a department, a sales outlet, a factory, etc.</p><p>   Otherwise, profits are taxed in another jurisdiction, but only a part related to a permanent establishment. A permanent establishment is an office, a department, a sales outlet, a factory, etc.</p><p>   As you can see, the Singapore government is very interested in ensuring that all taxpayers are fully aware of and apply new rules. This significantly distinguishes it from the governments of many other countries, for example, Russian, where they mostly intimidate their taxpayers.</p><p>  Against the backdrop of this approach of the government, it is not surprising that according to a study by the British bank HSBC, Singapore for the second consecutive year is the most ideal place for the life of expats. It took first place in the ranking of countries with better living conditions for visiting employees. The comparison of different countries in this rating was based on the following criteria: quality of life, living conditions (security, attitude of the local population to visitors, medicine, real estate) and the economy (career, personal finance, local economy).</p><p></p><p style="text-align: center;"><em>For more information, you can contact with CASTLE FAMILY OFFICE experts via email:  <span lang="EN-US"><span face="Calibri" size="3"><strong><a href="mailto:info@castle-familyoffice.sg">info@castle-familyoffice.sg</a></strong></span></span></em></p>