6 December 2016
On 25 November 2016, the Protocol amending the standing Agreement for the avoidance of double taxation (DTA) between Singapore and the Russia came into force. Its provisions will take effect from 1 January 2017.
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) 5% 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 original DTA was signed on 9 September 2002.
The full text of the Protocol is available on the IRAS’s website.