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1Article 1 · personal scope2Article 2 · taxes covered3Article 3 · general definitions4Article 4 · residence5Article 5 · permanent establishment6Article 6 · income from immovable property7Article 7 · business profits8Article 8 · shipping and air transport9Article 9 · associated enterprises10Article 10 · dividends11Article 11 · interest12Article 12 · royalties13Article 13 · capital gains14Article 14 · independent personal services15Article 15 · dependent personal services16Article 16 · directors’ fees17Article 17 · artistes and sportsmen18Article 18 · pensions19Article 19 · government service20Article 20 · students and trainees21Article 21 · teachers22Article 22 · other income23Article 23 · elimination of double taxation24Article 24 · limitation of relief25Article 25 · non-discrimination26Article 26 · mutual agreement procedure27Article 27 · exchange of information28Article 28 · members of diplomatic or permanent missions and consular posts29Article 29 · entry into force30Article 30 · terminationPreamble · Title, publisher explanation and complete preambleSignature · Signature and authentic-language clauseExchange of notes · Integral exchange of notes I and II

30 articles · English

Source & edition
Country pairs / United Kingdom / Singapore

United Kingdom / Singapore · United Kingdom–Singapore 1997 Agreement: official MLI synthesis

Article 25 · non-discrimination

English · synthesized source publication

Unreviewed · applicability unverifiedOfficial MLI synthesis
Original & source
§
- (1) Nationals of a Contracting State shall not be subjected in the other Contracting State to any taxation or any requirement connected therewith, which is other or more burdensome than the taxation and connected requirements to which nationals of that other State in the same circumstances, in particular with respect to residence, are or may be subjected.
§
- (2) The taxation on a permanent establishment which an enterprise of a Contracting State has in the other Contracting State shall not be less favourably levied in that other State than the taxation levied on enterprises of that other State carrying on the same activities.
§
- (3) Enterprises of a Contracting State, the capital of which is wholly or partly owned or controlled, directly or indirectly, by one or more residents of the other Contracting State, shall not be subjected in the first-mentioned State to any taxation or any requirement connected therewith which is other or more burdensome than the taxation and connected requirements to which other similar enterprises of the first mentioned State are or may be subjected. They may also consult together for the elimination of double taxation in cases not provided for in the Agreement.
§
- (4) Nothing in this Article shall be construed as obliging a Contracting State to grant to:
§
- (a) individual residents of the other Contracting State any personal allowances, reliefs and reductions for tax purposes on account of civil status or family responsibilities which it grants to its own residents; or
§
- (b) nationals of the other Contracting State those personal allowances, reliefs and reductions for tax purposes which it grants to its own nationals who are not resident in that Contracting State or to such other persons as may be specified in the taxation laws of that Contracting State
§
- (5) Where a Contracting State grants tax incentives exclusively to its nationals designed to promote economic or social development in accordance with its national policy and criteria that limitation shall not be construed as discrimination under this Article.
§
- (6) The provisions of this Article shall apply to the taxes which are the subject of this Agreement.
Citation to select or copy

United Kingdom / Singapore; HMRC, Synthesised text of the Multilateral Instrument and the 1997 UK-Singapore Double Taxation Agreement; edition Official MLI synthesis of 1997 Agreement as amended by 2009 and 2012 Protocols; HMRC updated 20 May 2019; article 25; English; unreviewed source text, current applicability unverified; /editions/gb-sg-1997-hmrc-mli-synthesis-html-v1/en/articles/article-25/

Disclaimers

Unreviewed machine transcription. Not a verified current-law consolidation or legal advice. Later changes may be missing.

Language switching retains source identifiers only. This is not reviewed legal or translational equivalence.

Page links are source references, not verified paragraph correspondence. Formatting and extraction errors may remain.

Noindex is not access control. This is a research preview, not a statement of authoritative or current law.

Source & edition

HMRC, Synthesised text of the Multilateral Instrument and the 1997 UK-Singapore Double Taxation Agreement

  • Official online text · retained capture Official source website ↗

    SHA-256 c1bba8057470dbfe9d73303464dc36f7d22c246c4216f2285a8f35d69d72b201

    Digest scope: retained online-source capture; no PDF binary verification

Edition
Official MLI synthesis of 1997 Agreement as amended by 2009 and 2012 Protocols; HMRC updated 20 May 2019
Text available here
English
Review
Unreviewed; qualified human review pending
Current applicability
Not verified
Signature
1997-02-12

Languages recorded in source metadata: English. This is not a promise of available text or a translation.

Edition notes and known limitations

Official HTML text capture, not Original PDF; human wording and current-law certification not claimed.

Block IDs are navigation aids, never invented legal paragraph numbers. Native extraction can flatten ordered-list styling; only printed source labels are retained.

Complete preamble, closing and all supplied integral protocol/notes are retained separately and searchable within this source.

Source spelling and apparent date typo “Singapore 2th February 1997” in first note retained verbatim; no editorial repair.

Publisher synthesis, not an authentic treaty instrument. MLI replacement text and explanations are retained; original boxes/layout are not reproduced. Authentic Convention and MLI texts take precedence.

Source authority, text completeness and currentness still require human review.

Retained metadata & integrity record

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