The Government of the Republic of Singapore and the Government of Canada have entered into an agreement to avoid double taxation and to prevent fiscal evasion. This Convention shall apply to persons who are residents of one or both of the Contracting States.
Taxes covered are on income imposed on behalf of each Contracting State, irrespective of the manner in which they are levied. There shall be regarded as taxes on income all taxes imposed on total income or on elements of income, including taxes on gains from the alienation of movable or immovable property as well as taxes on capital appreciation.
The existing taxes to which the Convention shall apply are, in particular:
(a) In the case of Canada:
The income taxes imposed by the Government of Canada
(hereinafter referred to as "Canadian tax")
(b) In the case of Singapore:
The income tax
(hereinafter referred to as "Singapore tax").
The term "citizen" means:
- Any individual possessing the citizenship of a Contracting State.
- Any legal person, partnership and association deriving its status as such from the law in force in a Contracting 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.
- However, such dividends may be taxed in the Contracting State of which the company paying the dividends is a resident, and according to the law of that State; but where the resident of the other Contracting State is the beneficial owner of the dividends, then, subject to the provisions of Article 21 of this Convention, the tax so charged shall not exceed 15 per cent of the gross amount of the dividends. The provisions of this paragraph shall not affect the taxation of the company on the profits out of which the dividends are paid.
- The term "dividends" as used in this Article means income from shares, mining shares, founders' shares or other rights, not being debt-claims, participating in profits, as well as income assimilated to income from shares by the taxation law 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.
- Such interest may be taxed in the Contracting State in which it arises and according to the law of that State; but the tax so charged shall, provided that the interest is taxable in the other Contracting State, not exceed 15 per cent of the gross amount of the interest.
- 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, as well as income assimilated to income from money lent by the taxation law of the State in which the income arises.
Termination
In Singapore:
In respect of tax for years of assessment beginning on or after the first day of January in the calendar year next following that in which the notice is given.
In Canada:
(i) In respect of tax withheld at the source on amounts paid or credited to non-residents on or after the first day of January in the calendar year next following that in which the notice is given;
(ii) In respect of other Canadian tax for taxation years beginning on or after the first day of January in the calendar year next following that in which the notice is given.
