Singapore has participated in the negotiation of the Multilateral Convention to Implement Tax Treaty Related Measures to Prevent Base Erosion and Profit Shifting (“Multilateral Instrument” or “MLI”). The MLI is intended to allow jurisdictions to swiftly amend their tax treaties to implement the tax treaty related Base Erosion and Profit Shifting (BEPS) recommendations.
On or about 1 April 2019, the amendments made by the MLI to Singapore’s DTAs with Australia, Austria, France, Isle of Man, Israel, Japan, Jersey, Lithuania, Malta, New Zealand, Poland, Slovak Republic, Slovenia and the United Kingdom took effect and will fall under the mutual agreement procedure regardless of the basis period to which the case relates:
- Income Tax Act — Income Tax (Singapore — France) (Avoidance of Double Taxation Convention) (Modifications to Implement Multilateral Instrument) (Amendment) Order 2019
- Income Tax Act — Income Tax (Singapore — New Zealand) (Avoidance of Double Taxation Agreement) (Modifications to Implement Multilateral Instrument) (Amendment) Order 2019
- Income Tax Act — Income Tax (Singapore — United Kingdom) (Avoidance of Double Taxation Agreement) (Modifications to Implement Multilateral Instrument) (Amendment) Order 2019
- Income Tax Act — Income Tax (Singapore — Australia) (Avoidance of Double Taxation Agreement) (Modifications to Implement Multilateral Instrument) (Amendment) Order 2019.
The above Orders are deemed to have come into operation on 1 April 2019.
Source: IRAS website, 1 April 2019