On or about 31 December 2019, in line with Singapore’s commitment to implement the minimum standard on preventing treaty abuse, Singapore has participated in the negotiation of Multilateral Convention to Implement Tax Treaty Related Measures to Prevent Base Erosion and Profit Shifting (“MLI”). The MLI intends to allow jurisdictions to swiftly amend their tax treaties to implement the tax treaty-related Base Erosion and Profit Shifting (BEPS) recommendations. The MLI also improves on dispute resolution mechanisms.
The IRAS has listed the Double taxation agreements (DTAs), and Singapore intends to amend them using the MLI after the point of ratification on 21 December 2018.
On 1 January 2020, the amendments made by the MLI to Singapore’s DTA with Denmark took effect on that date.
The DTAs will only be amended if Singapore’s treaty partners also choose to amend the DTAs using the MLI, and the amended DTAs will be referred to as Covered Tax Agreements under the MLI.
A Covered Tax Agreement will be amended only if both treaty partners share the same position on the provisions of the MLI and the agreed changes will come into effect after the treaty partner has ratified the MLI.
For more information, please visit the IRAS website.
Source: IRAS website, 31 December 2019