Singapore and Russia revise DTA

24 November 2015

On 17 November 2015, Singapore and Russia signed a Protocol to amend the existing Singapore – Russia Avoidance of Double Taxation Agreement (DTA).

Amongst other changes, the Protocol lengthens the threshold period for determining the presence of a permanent establishment and lowers the withholding tax rates for dividends, interest and royalties.

The withholding tax rates under the revised treaty are as follows:

  • Dividends —

(a) (i) % of the gross amount of the dividends if the beneficial owner of the dividends is a company which holds directly at least 15% of the capital of the company paying the dividends; (ii) 10% of the gross amount of the dividends in all other cases;

(b) in the case of distributions paid by the real estate investment fund: 10% of the gross amount of the distributions.

  • Royalties — 5% of the gross amount of the royalties
  • Interest — interest arising in a Contracting State and paid to a resident of the other Contracting State shall be taxable only in that other State.

The DTA has yet to be ratified and therefore does not have the force of law. The full text of the DTA is available on the IRAS website.

The original DTA was signed on 9 November 2002.

Source: IRAS