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### Synthesised text of the MLI and the agreement between the Government of the United Kingdom of Great Britain and Northern Ireland and the Government of the Republic of Singapore for the avoidance of double taxation and the prevention of fiscal evasion with respect to taxes on income and capital gains
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#### General disclaimer on the Synthesised text document
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This document presents the synthesised text for the application of the Agreement between the Government of the United Kingdom of Great Britain and Northern Ireland and the Government of the Republic of Singapore for the Avoidance of Double Taxation and the Prevention of Fiscal Evasion with respect to Taxes on Income and on Capital Gains signed on 12 February 1997 and the Protocols signed on 24 August 2009 and 15 February 2012 (together the ‘Agreement’), as modified by the Multilateral Convention to Implement Tax Treaty Related Measures to Prevent Base Erosion and Profit Shifting signed by the United Kingdom and Singapore on 7 June 2017 (the ‘MLI’).
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The document was prepared on the basis of the MLI position of the United Kingdom submitted to the Depositary upon ratification on 29 June 2018 and of the MLI position of Singapore submitted to the Depositary upon ratification on 21 December 2018. These MLI positions are subject to modifications as provided in the MLI. Modifications made to MLI positions could modify the effects of the MLI on the Agreement.
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The authentic legal texts of the Agreement and the MLI take precedence and remain the legal texts applicable.
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The provisions of the MLI that are applicable with respect to the provisions of the Agreement are included in boxes throughout the text of this document in the context of the relevant provisions of the Agreement. The boxes containing the provisions of the MLI have generally been inserted in accordance with the ordering of the provisions of the 2017 OECD Model Tax Convention.
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Changes to the text of the provisions of the MLI have been made to conform the terminology used in the MLI to the terminology used in the Agreement (such as ‘Covered Tax Agreement’ and ‘Agreement’, ‘Contracting Jurisdictions’ and ‘Contracting States’), to ease the comprehension of the provisions of the MLI. The changes in terminology are intended to increase the readability of the document and are not intended to change the substance of the provisions of the MLI. Similarly, changes have been made to parts of provisions of the MLI that describe existing provisions of the Agreement: descriptive language has been replaced by legal references of the existing provisions to ease the readability.
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In all cases, references made to the provisions of the Agreement or to the Agreement must be understood as referring to the Agreement as modified by the provisions of the MLI, provided such provisions of the MLI have taken effect.
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### References:
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The copies of the legal texts of the MLI and the Agreement can be found at the following links:
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The MLI:
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[http://www.oecd.org/tax/treaties/multilateral-convention-to-implement-tax-treaty-related measures-to-prevent-BEPS.pdf](http://www.oecd.org/tax/treaties/multilateral-convention-to-implement-tax-treaty-related%20measures-to-prevent-BEPS.pdf)
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In the United Kingdom: [http://www.legislation.gov.uk/uksi/1997/2988/contents/made](http://www.legislation.gov.uk/uksi/1997/2988/contents/made) [http://www.legislation.gov.uk/uksi/2010/2685/pdfs/uksi_20102685_en.pdf](http://www.legislation.gov.uk/uksi/2010/2685/pdfs/uksi_20102685_en.pdf) [http://www.legislation.gov.uk/uksi/2012/3078/pdfs/uksi_20123078_en.pdf](http://www.legislation.gov.uk/uksi/2012/3078/pdfs/uksi_20123078_en.pdf)
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In Singapore: https://sso.agc.gov.sg/SL/134-OR30B?DocDate=19980615 [https://sso.agc.gov.sg/SL/ITA1947-S752-2010?DocDate=20101209](https://sso.agc.gov.sg/SL/ITA1947-S752-2010?DocDate=20101209) [https://sso.agc.gov.sg/SL/ITA1947-S658-2012?DocDate=20121227](https://sso.agc.gov.sg/SL/ITA1947-S658-2012?DocDate=20121227) [https://sso.agc.gov.sg/SL/ITA1947-S259-2019?DocDate=2019040](https://sso.agc.gov.sg/SL/ITA1947-S259-2019?DocDate=2019040)
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The MLI position of the United Kingdom submitted to the Depositary upon ratification on 29 June 2018 and of the MLI position of Singapore submitted to the Depositary upon ratification on 21 December 2018 can be found on the MLI Depositary (OECD) webpage.
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#### Disclaimer on the entry into effect of the provisions of the MLI
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The provisions of the MLI applicable to the Agreement do not take effect on the same dates as the original provisions of the Agreement. Each of provisions of the MLI could take effect on different dates, depending on the types of taxes involved (taxes withheld at source or other taxes levied) and on the choices made by the United Kingdom and Singapore in their MLI positions.
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Dates of the deposit of instruments of ratification, acceptance or approval: 29 June 2018 for the United Kingdom and 21 December 2018 for Singapore.
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Entry into force of the MLI: 1 October 2018 for the United Kingdom and 1 April 2019 for Singapore.
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Unless it is stated otherwise elsewhere in this document, the provisions of the MLI have effect with respect to the Agreement:
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- In the United Kingdom and Singapore, for taxes withheld at source, from 1 January 2020;
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- In the United Kingdom, from 1 April 2020 for corporation tax and from 6 April 2020 for income tax and capital gain tax; and
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- In Singapore, for other taxes for basis periods beginning on or after 1 October 2019.
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### Agreement between the Government of the United Kingdom of Great Britain and Northern Ireland and the Government of the Republic of Singapore for the avoidance of double taxation and the prevention of fiscal evasion with respect to taxes on income and capital gains
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The Government of the United Kingdom of Great Britain and Northern Ireland and the Government of the Republic of Singapore:
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[REPLACED by paragraph 1 of Article 6 of the MLI] [Desiring to conclude an Agreement for the avoidance of double taxation and the prevention of fiscal evasion with respect to taxes on income and on capital gains;]
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The following paragraph 1 and paragraph 3 of Article 6 of the MLI replace the text referring to an intent to eliminate double taxation in the preamble of this Agreement:
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Article 6 of the MLI – purpose of a covered tax agreement
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Intending to eliminate double taxation with respect to the taxes covered by [the Agreement] without creating opportunities for non-taxation or reduced taxation through tax evasion or avoidance (including through treaty-shopping arrangements aimed at obtaining reliefs provided in [the Agreement] for the indirect benefit of residents of third jurisdictions).
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Desiring to further develop their economic relationship and to enhance their co operation in tax matter.
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Have agreed as follows: