The Government of the Republic of Singapore and the Government of the Russian Federation have entered into an Agreement to avoid double taxation and prevent fiscal evasion. This Agreement shall apply to persons who are residents of one or both of the Contracting States.
Taxes Covered
The Agreement applies to taxes on income imposed in each Contracting State, in line with the laws of each Contracting State, in spite of the manner in which they are levied.
Taxes on income
Personal Scope
This Agreement shall apply to persons who are residents of one or both of the Contracting States.
Taxes Covered
- The Agreement applies to taxes on income imposed in each Contracting State, in line with the laws of each Contracting State, in spite of the manner in which they are levied.
- Taxes on income imposed in each Contracting State, in accordance with the laws of each Contracting State.
- Taxes on income are those imposed on total income or on elements of income, which includes taxes on gains from the alienation of movable or immovable.
The existing taxes to which the Agreement apply are
In the case of the Russian Federation:
(i) Tax on profits (income) of enterprises and organizations
(ii) The income tax on individuals
(hereinafter referred to as “Russian tax”)
In the case of Singapore:
The income tax
(hereinafter referred to as “Singapore tax”).
The term “nationals” means:
- All individuals possessing the citizenship of a Contracting State
- All legal persons, partnerships and associations deriving their status as such from the laws in force in a Contracting State
The term “competent authority” means:
- In the case of the Russian Federation - the Ministry of Finance or its authorized representative
- In the case of Singapore, the Minister for Finance or his authorized representative.
Resident
- For the purposes of this Agreement, the term “resident of a Contracting State” means any person who, under the law of that State, is liable to tax therein by reason of his domicile, residence, place of management, place of registration or any other criterion of a similar nature, and also includes that State 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.
- 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 State, but if the recipient is the beneficial owner of the dividends the tax so charged shall not exceed:
- 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 taxation laws of the Contracting 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 Contracting State.
- However, such interest may also be taxed in the Contracting State in which it arises and according to the laws of that State, but if the recipient is the beneficial owner of the interest the tax so charged shall not exceed 7.5 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, and in particular, income from government securities, bonds or debentures, including premiums and prizes attaching to such securities, bonds or debentures.
Termination
This Agreement shall remain in force indefinitely but either of the Contracting States may terminate the Agreement through diplomatic channels, by giving to the other Contracting State written notice of termination at least six months before the end of any calendar year after the expiration of five years from the date on which the Agreement enters into force. In such event, the Agreement shall cease to have effect in respect of income derived on or after the first day of January of the calendar year next following that in which the notice of termination is given.
