- (1) Subject to the provisions of the law of the United Kingdom regarding the allowance as a credit against United Kingdom tax of tax payable in a territory outside the United Kingdom or, as the case may be, regarding the exemption from United Kingdom tax of a dividend arising in a territory outside the United Kingdom (which shall not affect the general principle hereof):
- (a) Singapore tax payable under the laws of Singapore and in accordance with this Agreement, whether directly or by deduction, on profits, income or chargeable gains from sources within Singapore (excluding in the case of a dividend tax payable in respect of the profits out of which the dividend is paid) shall be allowed as a credit against any United Kingdom tax computed by reference to the same profits, income or chargeable gains by reference to which the Singapore tax is computed
- (b) a dividend which is paid by a company which is a resident of Singapore to a company which is a resident of the United Kingdom shall be exempted from United Kingdom tax, when the conditions for exemption under the law of the United Kingdom are met
- (c) in the case of a dividend not exempted from tax under subparagraph (b) above (because the conditions for exemption under the law of the United Kingdom are not met) which is paid by a company which is a resident of Singapore to a company which is a resident of the United Kingdom and which controls directly or indirectly at least 10% of the voting power in the company paying the dividend, the credit mentioned in subparagraph (a) above shall also take into account the Singapore tax payable by the company in respect of its profits out of which such dividend is paid
- (2) In Singapore, double taxation shall be avoided as follows:
- (a) Where a resident of Singapore derives income from the United Kingdom which, in accordance with the provisions of this Agreement, may be taxed in the United Kingdom, Singapore shall, subject to its laws regarding the allowance as a credit against Singapore tax of tax payable in any country other than Singapore, allow the United Kingdom tax paid, whether directly or by deduction, as a credit against the Singapore tax payable on the income of that resident. Where such income is a dividend paid by a company which is a resident of the United Kingdom to a resident of Singapore which is a company owning directly or indirectly not less than 10% of the share capital of the first-mentioned company, the credit shall take into account the United Kingdom tax paid 34 by that company on the portion of its profits out of which the dividend is paid
- (b) Where a resident of Singapore derives income from the United Kingdom, Singapore shall, subject to the conditions for exemption of income received from outside Singapore provided for in the Singapore Income Tax Act being satisfied, exempt such income from tax in Singapore
- (3) For the purposes of paragraphs (1) and (2) of this Article, profits, income and capital gains owned by a resident of a Contracting State which may be taxed in the other Contracting State in accordance with this Agreement shall be deemed to arise from sources in that other Contracting State.