Income Tax (Singapore — Netherlands) (Avoidance of Double Taxation Convention) (Modifications to Implement Multilateral Instrument) Order 2019

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No. S 458

Income Tax Act

(CHAPTER 134)

Income Tax (Singapore — Netherlands)
(Avoidance of Double Taxation Convention)
(Modifications to Implement Multilateral
Instrument) Order 2019

In exercise of the powers conferred by section 49(7) of the Income Tax Act, the Minister for Finance makes the following Order:

Citation and commencement

1. This Order is the Income Tax (Singapore — Netherlands) (Avoidance of Double Taxation Convention) (Modifications to Implement Multilateral Instrument) Order 2019 and comes into operation on 1 July 2019.

Purpose

2.—(1) This Order amends the arrangements made between the Government of the Republic of Singapore and the Government of the Kingdom of the Netherlands as specified in the Schedule to the Income Tax (Singapore — Netherlands) (Avoidance of Double Taxation Convention) Order 1971 (O 20) (called in this Order the Convention), as modified —

(a)	by the Protocol specified in the Schedule to the Income Tax (Singapore — Netherlands) (Avoidance of Double Taxation Convention) (Supplementary) Order 1994 (O 20A); and
(b)	by the Protocol specified in the Schedule to the Income Tax (Singapore — Netherlands) (Avoidance of Double Taxation Convention) Order 2010 (G.N. No. S 135/2010).

(2) The purpose of this Order is to amend the Convention to give effect to Singapore’s obligations under the Multilateral Convention to Implement Tax Treaty Related Measures to Prevent Base Erosion and Profit Shifting done at Paris on 24 November 2016 (as amended from time to time).

Amendment of Convention

3. The provisions of the Convention are amended in the manner set out in the Schedule.

Entry into effect

4.—(1) Paragraph 3 of the Schedule has effect for a case presented on or after 1 July 2019 without regard to the basis period to which the case relates.

(2) Sub-paragraph (1) does not apply to a case that was not eligible to be presented immediately before 1 July 2019.

(3) Paragraph 4 of the Schedule has effect with respect to any tax paid, deemed paid or liable to be paid, before, on or after 1 July 2019.

(4) All other paragraphs of the Schedule have effect —

(a)	with respect to taxes withheld at source, in respect of amounts paid, deemed paid or liable to be paid (whichever is the earliest), on or after 1 January 2020; and
(b)	with respect to taxes other than those withheld at source, where the income is derived or received in a basis period beginning on or after 1 January 2020.

Made on 24 June 2019.

TAN CHING YEE

Permanent Secretary,
Ministry of Finance,
Singapore.

[R032.007.2629.V1; AG/LEGIS/SL/134/2015/3 Vol. 10]