All our DTAs contain a map article. A taxable person established in Singapore, who is subject to double taxation or considers that double taxation is imminent and considers that the taxation levied by the competent tax authorities does not comply with the provisions of the relevant DBA, may request IRAS to resolve the issue of double taxation under Article MAP. For more information, see the MAP. Find out which countries and territories have a DBA with New Zealand. Find out how DTAs offer more double taxation relief than is possible under national law. A DBA between Singapore and another jurisdiction serves to avoid double taxation of income received in one jurisdiction by a resident of the other jurisdiction. A DBA also highlights the tax rights between Singapore and its contractual partner on different types of income resulting from cross-border economic activities between the two jurisdictions. The agreements also provide for a reduction or exemption from tax on certain types of income. See Singapore`s list of DTAs, Treaties and EOI Arrangements. See the list of competent authorities in Singapore (PDF, 152KB) for the purposes of international tax treaties. In general, Singapore`s ATDs and EOI agreements contain provisions for the exchange of information for tax purposes, and this may take the form of an EOI on request, a spontaneous EOI or an automatic EOI. EOI partners can request information from the Comptroller of Income Tax.
Look at the management of information exchange for tax purposes. You need to know your tax resident status. This will help you understand how New Zealand`s tax laws and DTAs apply to you. In New Zealand, you are one: two parties are considered related if the first has a stake of 25% or more in the second person or if there is a third person holding a stake of 25% or more in both. A person is treated as holding a percentage of a stake in another person where that person holds, directly or indirectly, through an interest in other persons, that percentage of that person`s voting rights or the value of any interests of that person. The same threshold applies to other businesses, such as partnerships and trusts. – Issued on January 1, 2015 or after January 1, 2015, but before April 1, 2017 Once you have established your tax resident status, you can see how DTAS can affect how certain types of income are taxed. It is also possible to be fiscally resident both in New Zealand and in another country or territory. The final report published by the OECD in October 2015 on BEPS Action 5 “Tackling harmful tax practices more effectively by taking into account transparency and substance” establishes an agreed framework for the mandatory spontaneous exchange of information on certain decisions.
In this context, Singapore has undertaken to spontaneously exchange the following categories of decisions: another recent amendment, increasingly introduced in all DTAs, is to allow a taxable person to challenge a POP case before one of the competent authorities. . . .
