Double Taxation Agreement Between Singapore and Japan - Double Tax Avoidance Agreement Between Singapore and Japan

The Government of the Republic of Singapore and the Government of Japan have agreed to enter into an agreement to avoid double taxation and to prevent fiscal evasion.

Article 1

This Agreement shall apply to persons who are residents of one or both of the Contracting States.

ARTICLE 2

This Agreement shall apply to the following taxes:

(a) In Japan:

(i) The income tax;

(ii) The corporation tax; and

(iii) The local inhabitant taxes

(hereinafter referred to as "Japanese tax")

(b) In Singapore:

The income tax (hereinafter referred to as "Singapore tax").

Article 3

The term "Japan", when used in a geographical sense, means all the territory of Japan, including its territorial sea, in which the laws relating to Japanese tax are in force, and all the area beyond its territorial sea, including the sea-bed and subsoil thereof, over which Japan has jurisdiction in accordance with international law and in which the laws relating to Japanese tax are in force.
The term "Singapore" means the Republic of Singapore.
The terms "a Contracting State" and "the other Contracting State" mean Singapore or Japan, as the context requires.
The term "tax" means Singapore tax or Japanese tax, as the context requires.
The term "person" includes an individual, a company and any other body of persons.
The term "company" means anybody corporate or any entity which is treated as a body corporate for tax purposes.
The terms "enterprise of a Contracting State" and "enterprise of the other Contracting State" mean respectively an enterprise carried on by a resident of a Contracting State and an enterprise carried on by a resident of the other Contracting State.
The term "nationals" means all individuals possessing the nationality of either Contracting State and all juridical persons created or organized under the laws of that Contracting State and all organizations without juridical personality treated for the purposes of tax of that Contracting State as juridical persons created or organized under the laws of that Contracting State.

Article 4

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 Contracting State.
However, 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 Contracting State, but if the recipient is the beneficial owner of the dividends the tax so charged shall not exceed:
(a) 5 per cent of the gross amount of the dividends if the beneficial owner is a company which owns at least 25 per cent of the voting shares of the company paying the dividends during the period of six months immediately before the end of the accounting period for which the distribution of profits takes place
(b) 15 per cent of the gross amount of the dividends in all other cases.

Article 5

Interest arising in a Contracting State and paid to a resident of the other Contracting State may be taxed in that other Contracting State.
Such interest may also be taxed in the Contracting State in which it arises, and according to the laws of that Contracting State, but if the recipient is the beneficial owner of the interest, the tax so charged shall not exceed 10 per cent of the gross amount of the interest.

Article 6

This Agreement shall continue in effect indefinitely but either Contracting State may, on or before the thirtieth day of June of any calendar year beginning after the expiration of a period of five years from the date of its entry into force, give to the other Contracting State, through the diplomatic channel, written notice of termination and, in such event, this Agreement shall cease to have effect:

In Japan:

As regards income for any taxable year beginning on or after the first day of January of the calendar year next following that in which the notice of termination is given.

In Singapore:
in respect of Singapore tax for the year of assessment beginning on or after the first day of January in the second calendar year following the year in which the notice of termination is given.