The Government of the Republic of Singapore and the Hong Kong Special Administrative Region 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.
The taxes to which the Agreement shall apply are:
- In case of Hong Kong Special Administrative Region, profits tax and salaries tax
- In Singapore it is the income tax.
The Agreement shall also apply to any identical or similar taxes that are imposed by either Contracting Party after the Agreement has been signed.
General Definitions
- The term "A Contracting Party" is either the Hong Kong Special Administrative Region or Singapore.
- The term "person" includes an individual, a company and any other body of persons, whether incorporated or unincorporated.
The term "an enterprise of a Contracting Party" means an enterprise by:
- A company or body of persons managed and controlled in the Hong Kong Special Administrative Region or Singapore
An individual who
- In Hong Kong Special Administrative Region is a permanent or temporary resident for the purpose of the Inland Revenue Ordinance;
- In Singapore is a resident for the purpose of Singapore income tax.
Mutual Agreement Procedure
The competent authorities of the Contracting Parties shall endeavor to resolve by consultation any difficulties or doubts arising as to the interpretation or application of this Agreement.
Entry into Force
- In the Hong Kong Special Administrative Region, for any year of assessment beginning on or after 1 April in the calendar year next following that in which this Agreement enters into force;
- In Singapore, in respect of tax chargeable for any year of assessment beginning on or after 1 January in the second calendar year next following the year in which this Agreement enters into force.
Termination
- In the Hong Kong Special Administrative Region, for any year of assessment beginning on or after 1 April in the calendar year next following that in which notice is given;
- In Singapore, in respect of tax chargeable for any year of assessment beginning on or after 1 January in the second calendar year next following the year in which notice is given.
