Australia / Singapore · English
Australia–Singapore 1969 Agreement
Select an article, or search its number, title or wording.
Unreviewed · applicability unverified
Contents
Article 1 · 1. The existing taxes to which this Agreement applies are—
Article 2 · 1. In this Agreement, unless the context otherwise requires—
Article 3 · 1. For the purposes of this Agreement—
Article 4 · 1. For the purposes of this Agreement the term “permanent establishment” in relation to an enterprise means a fixed place of trade or business in which the trade or business of the enterprise is wholly or partly carried on.
Article 5 · 1. Profits of an Australian enteprise shall not be subject to Singapore tax unless the enterprise carries on trade or business in Singapore through a permanent establishment in Singapore. If it carries on trade or business as aforesaid, Singapore tax may be imposed on those profits but only on so much of them as is attributable to that permanent establishment.
Article 6 · 1. Where—
Article 7 · 1. The tax payable in a Contracting State by a resident of the other Contracting State in respect of profits from the operation of ships, other than profits from voyages or operations of ships confined solely to places in the first-mentioned Contracting State, shall not exceed half the amount which would be payable in respect of those profits but for this paragraph.
Article 8 · 1. The Australian tax on dividends, being dividends paid by a company which is a resident of Australia, derived by a Singapore resident who is beneficially entitled to the dividends, shall not exceed 15 per centum of the gross amount of the dividends.
Article 9 · 1. The Australian tax on interest derived by a Singapore resident who is beneficially entitled to the interest shall not exceed 10 per centum of the gross amount of the interest.
Article 10 · 1. The Australian tax on royalties derived by a Singapore resident who is beneficially entitled to the royalties shall not exceed 10 per centum of the gross amount of the royalties.
Article 11 · 1. Subject to this Article and to Articles 12, 13 and 14 remuneration or other income derived by an individual who is a resident of one of the Contracting States in respect of personal (including professional) services shall be subject to tax only in that Contracting State unless the services are performed or exercised in the other Contracting State. If the services are so performed or exercised such remuneration or other income as is derived therefrom shall be deemed to have a source in, and may be taxed in, that other Contracting State.
Article 12 · 1. Remuneration or other income derived by an individual who is a resident of one of the Contracting States in respect of personal (including professional) services performed or
Article 13 · 1. A pension or an annuity, derived from sources within one of the Contracting States by an individual who is a resident of the other Contracting State, shall be exempt from tax in the first-mentioned Contracting State.
Article 14 · 1. Remuneration (other than pensions) paid by the Government of the Commonwealth or of any State of the Commonwealth to any individual for services rendered to that Government in the discharge of governmental functions shall be exempt from Singapore tax, except where the individual is resident in Singapore and is not an Australian citizen.
Article 15 · A student or trainee who is, or was immediately before visiting one of the Contracting States, a resident of the other Contracting State and is present in the first-mentioned Contracting State solely for the purpose of his education or training shall not be taxed in that first-mentioned Contracting State on payments which he receives for the purpose of his maintenance, education or training provided that such payments are made to him from outside that first-mentioned Contracting State.
Article 16 · 1. This Article shall apply to a person who is a resident of Australia and is also resident in Singapore.
Article 17 · 1. For the purposes of this Agreement—
Article 18 · 1. Subject to any provisions of the law of the Commonwealth which may from time to time be in force and which relate to the allowance of a credit against Australian tax of tax paid in a country outside Australia (which shall not affect the general principle hereof), Singapore tax paid, whether directly or by deduction, in respect of income derived by a resident of Australia from sources within Singapore (excluding in the case of a dividend, tax paid in respect of the profits out of which the dividend is paid) shall be allowed as a credit against Australian tax payable in respect of that income.
Article 19 · 1. The competent authorities shall exchange such information (being information which is at their disposal under their respective taxation laws in the normal course of administration) as is necessary for carrying out the provisions of this Agreement or for the prevention of fraud or for the administration of statutory provisions against legal avoidance in relation to the taxes which are the subject of this Agreement.
Article 20 · 1. Where a taxpayer considers that the action of the competent authority in one of the Contracting States has resulted, or is likely to result, in double taxation contrary to the provisions of this Agreement, he shall be entitled to present the facts to the competent authority in the Contracting State of which he is a resident and, should the taxpayer’s claim be deemed worthy of consideration, the competent authority in that Contracting State shall endeavour to come to an agreement with the competent authority in the other Contracting State with a view to the avoidance of the double taxation in question.
Article 21 · This Agreement shall come into force on the date on which the last of all such things shall have been done in Australia and Singapore as are necessary to give the Agreement the force of law in Australia and Singapore so far as its provisions affect Australian tax and Singapore tax respectively and shall thereupon have effect—
Article 22 · This Agreement shall continue in effect indefinitely, but either Contracting State may, on or before 30th June in any calendar year give to the other Contracting State notice of termination and, in that event, this Agreement shall cease to be effective—