On or about 1 April 2019, amendments were made by the Multilateral Convention to Implement Tax Treaty Related Measures to Prevent Base Erosion and Profit Shifting (“Multilateral Instrument” or “MLI”) to Singapore’s DTAs.

Some of DTAs concluded by Singapore were amended by the MLI with Australia, Austria, France, Isle of Man, Israel, Japan, Jersey, Lithuania, Malta, New Zealand, Poland, Slovak Republic, Slovenia and the United Kingdom. They are amongst those 57 countries that are to be changed with the signing of the MLI.

6 countries are not be changed as they have not chosen Singapore as a covered tax agreement (CTA): Germany, Mauritius, Norway, Sweden, Switzerland and Tunisia.

A CTA will only be amended by the MLI if both treaty partners share the same position on the provisions of the MLI, and after both parties have deposited their instrument of ratification with the Secretary-General of the OCED. The amendments generally take effect from the basis period following the expiration of a period of six calendar months after the MLI enters into force for both jurisdictions.

23 countries are subject to the respective country signing the MLI: Albania, Bahrain, Bangladesh, Belarus, Brunei, Cambodia, Ecuador, Ethiopia, Ghana, Kenya, Laos, Libya, Mongolia, Morocco, Myanmar, Oman, Papua New Guinea, Philippines, Rwanda, Sri Lanka, Thailand, Uzbekistan and Vietnam.

Source: IRAS, 3 April 2019