Income Tax (Singapore — Ireland) (Avoidance of Double Taxation Agreement) Order 2011
WHEREAS it is provided by section 49 of the Income Tax Act that if the Minister by order declares that arrangements specified in the order have been made with the Government of any country outside Singapore with a view to affording relief from double taxation in relation to tax under the Act and any tax of a similar character imposed by the laws of that country, and that it is expedient that those arrangements should have effect, the arrangements shall have effect in relation to tax under the Act notwithstanding anything in any written law:
AND WHEREAS it is provided by section 105C of the Income Tax Act that the Minister may by order declare an avoidance of double taxation arrangement as a prescribed arrangement for the purposes of Part XXA of the Act:
AND WHEREAS by an Agreement dated 28th October 2010, between the Government of the Republic of Singapore and the Government of Ireland, arrangements were made, amongst other things, for the avoidance of double taxation:
AND WHEREAS by a Protocol dated 28th October 2010, between the Government of the Republic of Singapore and the Government of Ireland, the arrangements set out in the said Agreement were modified as prescribed in the said Protocol:
NOW, THEREFORE, it is hereby declared by the Minister for Finance —
(a)
that the arrangements specified in the Schedule to this Order have been made with the Government of Ireland;
(b)
that it is expedient that those arrangements should have effect notwithstanding anything in any written law; and
(c)
that those arrangements as modified by the said Protocol specified in the Schedule to this Order are a prescribed arrangement for the purposes of Part XXA of the Act.
Made this 31st day of March 2011.
PETER ONG
Permanent Secretary, Ministry of Finance, Singapore.