The Government of the Republic of Singapore and the Government of India have entered into an agreement to avoid double taxation and to prevent fiscal evasion. This Agreement shall apply to persons who are residents of one or both of the Contracting States.
In India:
- Income-tax including any surcharge thereon (hereinafter referred to as "Indian tax");
In Singapore:
- The income tax
Resident
The term “resident of a Contracting State" means any person who is a resident of a Contracting State in accordance with the taxation laws of that State.
Dividends
Dividends paid by a company which is a resident of a Contracting State to a resident of the other Contracting State may be taxed in that other State. But such dividends may also be taxed in the Contracting State of which the company paying the dividends is a resident and according to the laws of that state, but if the recipient is the beneficial owner of the dividends, the tax charged would exceed:
- 10% of the gross amount of the dividends if the beneficial owner is a company which owns at least 25% of the shares of the company paying the dividends
- 15% of the gross amount of the dividends in all other cases.
The term "dividends" as used in this Article means income from shares or other rights, not being debt-claims, participating in profits, as well as income from other corporate rights which is subjected to the same taxation treatment as income from shares by the laws of the State of which the company making the distribution is a resident.
Interest
Interest arising in a Contracting State and paid to a resident of the other Contracting State may be taxed in that other State.
But such interest may also be taxed in the Contracting State in which it arises and according to the laws of that State. But in case the beneficial owner of the interest is a resident of the other Contracting State, the tax charged should not exceed:
- 10% of the gross amount of the interest if such interest is paid on a loan granted by a bank carrying on a bona fide banking business or by a similar financial institution (including an insurance company)
- 15% of the gross amount of the interest in all other cases.
The term "interest" as used in this Article means income from debt-claims of every kind, whether or not secured by mortgage and whether or not carrying a right to participate in the debtor's profits; and in particular, income from government securities and income from bonds or debentures, including premiums and prizes attaching to such securities, bonds or debentures. Penalty charges for late payment shall not be regarded as interest for the purpose of this Article.
Termination
In India, in respect of income assessable for the assessment year commencing on the 1st day of April in the second calendar year following the calendar year in which the notice is given and the subsequent assessment years. In Singapore, in respect of income assessable for the year of assessment commencing on the 1st day of January in the second calendar year following the calendar year in which the notice is given and the subsequent years of assessment.
In India, in respect of income assessable for the assessment year commencing on the 1st day of April in the second calendar year following the calendar year in which the notice is given and the subsequent assessment years. In Singapore, in respect of income assessable for the year of assessment commencing on the 1st day of January in the second calendar year following the calendar year in which the notice is given and the subsequent years of assessment.
