Income Tax (Singapore — Germany) (Supplementary) (Avoidance of Double Taxation Agreement) Order 2021
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 have effect in relation to tax under the Act despite anything in any written law:
AND WHEREAS by an Agreement dated 28 June 2004, between the Government of the Republic of Singapore and the Federal Republic of Germany, arrangements were made, amongst other things, for the avoidance of double taxation:
AND WHEREAS by a Protocol dated 9 December 2019, between the Government of the Republic of Singapore and the Federal Republic of Germany, the arrangements set out in the said Agreement were modified as prescribed in the said Protocol:
AND WHEREAS after due consultation with the competent authority of Singapore, and by a Notification dated 16 August 2021 from the Federal Republic of Germany made through diplomatic channels in accordance with sub‑paragraph (bb) of sub‑paragraph (e) of paragraph 1 of Article 24 of the said Agreement, the arrangements set out in the said Agreement (as modified by the said Protocol) were modified as prescribed in the said Notification:
NOW, THEREFORE, it is declared by the Minister for Finance —
(a)
that the arrangements, as modified by the said Notification specified in the Schedule to this Order, have been made with the Federal Republic of Germany; and
(b)
that it is expedient that those arrangements should have effect from 1 January 2022 despite anything in any written law.
Made on 17 October 2021.
TAN CHING YEE
Permanent Secretary, Ministry of Finance, Singapore.