The Republic of Singapore and Germany desiring to conclude an agreement for the avoidance of double taxation with respect to taxes on income and on capital to promote their mutual economic relations, have agreed as follows:
Personal Scope
The agreement shall apply to persons who are residents of one or both of the Contracting States.
Taxes Covered
- The Agreement will apply to taxes on income and on capital imposed on behalf of a Contracting State, of a Land or a political subdivision or a local authority thereof' irrespective of the manner in which they are levied.
- There shall be regarded as taxes on income and on capital all taxes imposed on total income, on total capital, or on elements of income or of capital, including taxes on gains from the alienation of movable or immovable property and taxes on capital appreciation.
The existing taxes to which this Agreement shall apply are in particular:
In Germany:
- The income tax (Einkommensteuer),
- The corporation tax (Körperschaftsteuer),
- The capital tax (Vermögensteuer), and
- The trade tax (Gewerbesteuer)
- Including the supplements levied thereon
In Singapore:
- The income tax
The Agreement will also apply to any similar taxes which are imposed after the date of signature of the Agreement in addition to or in place of the existing taxes. The competent authorities of the Contracting States shall notify each other of any substantive changes which have been made in their respective taxation laws.
Resident
- The term "resident of a Contracting Side" refers to any person who under the laws of that State, is liable to tax therein by reason of his domicile, residence, place of management or any other criterion of a similar nature and also includes that State, a Land and any political subdivision or local authority or statutory body thereof.
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.
The dividends may also be taxed in the Contracting State, where the company paying the dividends is a resident and according to the laws of that state, provided the beneficial owner of the dividends is a resident of the other Contracting State, in such case the tax charged shall not exceed: - 5 per cent of the gross amount of the dividends if the beneficial owner holds directly at least 10 per cent of the capital of the company paying the dividends.
- 15 per cent of the gross amount of the dividends in all other cases.
Interest
Interest accrued in a Contracting State and paid to a resident of the other Contracting State may be taxed in that other State. Such interest may also be taxed in the Contracting State in which it accrues, in accordance with the laws of the State.
Interest accrued in a Contracting State and paid to a resident of the other Contracting State may be taxed in that other State. Such interest may also be taxed in the Contracting State in which it accrues, in accordance with the laws of the State.
