Prevention of Tax Treaty Abuse – Third Peer Review Report on Treaty Shopping

Singapore

A. Progress in the implementation of the minimum standard

Singapore has 88 tax agreements in force, as reported in its response to the Peer Review questionnaire. 28 of those agreements, the agreement with Australia, Austria, Belgium, Canada, Denmark, Finland, France, Georgia, Guernsey, India, Ireland, the Isle of Man, Israel, Japan, Jersey, Korea, Lithuania, Luxembourg, Malta, the Netherlands, New Zealand, Poland, the Slovak Republic, Slovenia, Turkmenistan*, Ukraine, the United Arab Emirates, and the United Kingdom, comply with the minimum standard1.

Singapore signed the MLI in 2017 and deposited its instrument of ratification on 21 December 2018. The MLI entered into force for Singapore on 1 April 2019.

Singapore is implementing the minimum standard in its tax agreements through the inclusion of the preamble statement and the PPT.2

The agreements modified by the MLI come into compliance with the minimum standard once the provisions of the MLI take effect.

B. Implementation issues

No jurisdiction has raised any concerns about their agreements with Singapore.

Summary of the jurisdiction response - Singapore

 

	Treaty partners	Compliance with the standard	If compliant, the alternative implemented	Signature of a complying instrument	The alternative implemented through the complying instrument (if not the MLI)	Comments
1	Albania	No	N/A	Yes	N/A	Singapore has included this treaty to be covered by MLI. However, treaty partner has not ratified MLI.
2	Australia	Yes	PPT alone	N/A	N/A
3	Austria	Yes	PPT alone	N/A	N/A
4	Bahrain	No	N/A	Yes	N/A	Singapore has included this treaty to be covered by MLI. However, treaty partner has not signed MLI.
5	Bangladesh*	No	N/A	Yes	N/A	Singapore has included this treaty to be covered by MLI. Treaty partner is not an IF member and has not signed MLI. (See Note 1)
6	Barbados	No	N/A	Yes	N/A	Singapore has included this treaty to be covered by MLI. However, treaty partner has not ratified MLI.
7	Belarus*	No	N/A	Yes	N/A	Singapore has included this treaty to be covered by MLI. Treaty partner is not an IF member and has not signed MLI. (See Note 1)
8	Belgium	Yes	PPT alone	N/A	N/A
9	Brunei Darussalam	No	N/A	Yes	N/A	Singapore has included this treaty to be covered by MLI. However, treaty partner has not signed MLI.
10	Bulgaria	No	N/A	Yes	N/A	Singapore has included this treaty to be covered by MLI. However, treaty partner has not ratified MLI.
11	Cambodia*	No	N/A	Yes	N/A	Singapore has included this treaty to be covered by MLI. Treaty partner is not an IF member and has not signed MLI. (See Note 1)
12	Canada	Yes	PPT alone	N/A	N/A
13	China (People's Republic of)	No	N/A	Yes	N/A	Singapore has included this treaty to be covered by MLI. However, treaty partner has not ratified MLI.
14	Chinese Taipei*	No	N/A	No	N/A	Treaty partner is not an IF member and has not signed MLI. (See Note 1)
15	Cyprus*	No	N/A	Yes	N/A	MLI will enter into effect after 30 June 2020.
16	Czech Republic	No	N/A	Yes	N/A	MLI will enter into force after 30 June 2020.
17	Denmark	Yes	PPT alone	N/A	N/A
18	Ecuador*	No	N/A	Yes	N/A	Singapore has included this treaty to be covered by MLI. Treaty partner is not an IF member and has not signed MLI. (See Note 1)
19	Egypt	No	N/A	Yes	N/A	Singapore has included this treaty to be covered by MLI. However, treaty partner has not ratified MLI.
20	Estonia	No	N/A	Yes	N/A	Singapore has included this treaty to be covered by MLI. However, treaty partner has not ratified MLI.
21	Ethiopia*	No	N/A	Yes	N/A	Singapore has included this treaty to be covered by MLI. Treaty partner is not an IF member and has not signed MLI. (See Note 1)
22	Fiji*	No	N/A	Yes	N/A	Singapore has included this treaty to be covered by MLI. Treaty partner is not an IF member and has not ratified MLI.
23	Finland	Yes	PPT alone	N/A	N/A
24	France	Yes	PPT alone	N/A	N/A
25	Georgia	Yes	PPT alone	N/A	N/A
26	Germany	No	N/A	Yes	N/A	Singapore has included this treaty to be covered by MLI but this treaty has been excluded from MLI by treaty partner. Protocol with BEPS MS signed.
27	Ghana*	No	N/A	Yes	N/A	Singapore has included this treaty to be covered by MLI. Treaty partner is not an IF member and has not signed MLI. (See Note 1)
28	Guernsey	Yes	PPT alone	N/A	N/A
29	Hungary	No	N/A	Yes	N/A	Singapore has included this treaty to be covered by MLI. However, treaty partner has not ratified MLI.
30	India	Yes	PPT alone	N/A	N/A
31	Indonesia	No	N/A	Yes	N/A	MLI will enter into force after 30 June 2020. Revised treaty with MS signed.
32	Ireland	Yes	PPT alone	N/A	N/A
33	Isle of Man	Yes	PPT alone	N/A	N/A
34	Israel	Yes	PPT alone	N/A	N/A
35	Italy	No	N/A	Yes	N/A	Singapore has included this treaty to be covered by MLI. However, treaty partner has not ratified MLI.
36	Japan	Yes	PPT alone	N/A	N/A
37	Jersey	Yes	PPT alone	N/A	N/A
38	Kazakhstan	No	N/A	Yes	N/A	Singapore has included this treaty to be covered by MLI. However, treaty partner has not ratified MLI.
39	Korea	Yes	PPT alone	N/A	N/A
40	Kuwait*	No	N/A	Yes	N/A	Singapore has included this treaty to be covered by MLI. Treaty partner is not an IF member and has not ratified MLI.
41	Lao People’s Democratic Republic*	No	N/A	Yes	N/A	Singapore has included this treaty to be covered by MLI. Treaty partner is not an IF member and has not signed MLI. (See Note 1)
42	Latvia	No	N/A	Yes	N/A	MLI will enter into effect after 30 June 2020.
43	Libya*	No	N/A	Yes	N/A	Singapore has included this treaty to be covered by MLI. Treaty partner is not an IF member and has not signed MLI. (See Note 1)
44	Liechtenstein	No	N/A	Yes	N/A	MLI will enter into effect after 30 June 2020.
45	Lithuania	Yes	PPT alone	N/A	N/A
46	Luxembourg	Yes	PPT alone	N/A	N/A
47	Malaysia	No	N/A	Yes	N/A	Singapore has included this treaty to be covered by MLI. However, treaty partner has not ratified MLI.
48	Malta	Yes	PPT alone	N/A	N/A
49	Mauritius	No	N/A	Yes	N/A	MLI will enter into effect after 30 June 2020.
50	Mexico	No	N/A	Yes	N/A	Singapore has included this treaty to be covered by MLI. However, treaty partner has not ratified MLI.
51	Mongolia	No	N/A	Yes	N/A	Singapore has included this treaty to be covered by MLI. However, treaty partner has not signed MLI.
52	Morocco	No	N/A	Yes	N/A	Singapore has included this treaty to be covered by MLI. However, treaty partner has not ratified MLI.
53	Myanmar*	No	N/A	Yes	N/A	Singapore has included this treaty to be covered by MLI. Treaty partner is not an IF member and has not signed MLI. (See Note 1)
54	Netherlands	Yes	PPT alone	N/A	N/A
55	New Zealand	Yes	PPT alone	N/A	N/A
56	Nigeria	No	N/A	Yes	N/A	Singapore has included this treaty to be covered by MLI. However, treaty partner has not ratified MLI.
57	Norway	No	N/A	Yes	N/A	Singapore has included this treaty to be covered by MLI but this treaty has been excluded from MLI by treaty partner. (See Note 1)
58	Oman	No	N/A	Yes	N/A	Singapore has included this treaty to be covered by MLI. However, treaty partner has not ratified MLI.
59	Pakistan	No	N/A	Yes	N/A	Singapore has included this treaty to be covered by MLI. However, treaty partner has not ratified MLI.
60	Panama	No	N/A	Yes	N/A	Singapore has included this treaty to be covered by MLI. However, treaty partner has not ratified MLI.
61	Papua New Guinea	No	N/A	Yes	N/A	Singapore has included this treaty to be covered by MLI. However, treaty partner has not ratified MLI.
62	Philippines*	No	N/A	Yes	N/A	Singapore has included this treaty to be covered by MLI. Treaty partner is not an IF member and has not signed MLI. (See Note 1)
63	Poland	Yes	PPT alone	N/A	N/A
64	Portugal	No	N/A	Yes	N/A	MLI will enter into effect after 30 June 2020.
65	Qatar	No	N/A	Yes	N/A	MLI will enter into effect after 30 June 2020.
66	Romania	No	N/A	Yes	N/A	Singapore has included this treaty to be covered by MLI. However, treaty partner has not ratified MLI.
67	Russia	No	N/A	Yes	N/A	MLI will enter into effect after 30 June 2020.
68	Rwanda*	No	N/A	Yes	N/A	Singapore has included this treaty to be covered by MLI. Treaty partner is not an IF member and has not signed MLI. (See Note 1)
69	San Marino	No	N/A	Yes	N/A	MLI will enter into force after 30 June 2020.
70	Saudi Arabia	No	N/A	Yes	N/A	MLI will enter into effect after 30 June 2020.
71	Seychelles	No	N/A	Yes	N/A	Singapore has included this treaty to be covered by MLI. However, treaty partner has not ratified MLI.
72	Slovak Republic	Yes	PPT alone	N/A	N/A
73	Slovenia	Yes	PPT alone	N/A	N/A
74	South Africa	No	N/A	Yes	N/A	Singapore has included this treaty to be covered by MLI. However, treaty partner has not ratified MLI.
75	Spain	No	N/A	Yes	N/A	Singapore has included this treaty to be covered by MLI. However, treaty partner has not ratified MLI.
76	Sri Lanka	No	N/A	Yes	N/A	Singapore has included this treaty to be covered by MLI. However, treaty partner has not signed MLI.
77	Sweden	No	N/A	Yes	N/A	Singapore has included this treaty to be covered by MLI but this treaty has been excluded from MLI by treaty partner. (See Note 1)
78	Switzerland	No	N/A	Yes	N/A	Singapore has included this treaty to be covered by MLI but this treaty has been excluded from MLI by treaty partner. (See Note 1)
79	Thailand	No	N/A	Yes	N/A	Singapore has included this treaty to be covered by MLI. However, treaty partner has not signed MLI.
80	Tunisia	No	N/A	Yes	N/A	Singapore has included this treaty to be covered by MLI. However, treaty partner has not ratified MLI and has not included this treaty to be covered by MLI. Singapore has approached treaty partner to include treaty in its instrument of ratification for the MLI.
81	Turkey	No	N/A	Yes	N/A	Singapore has included this treaty to be covered by MLI. However, treaty partner has not ratified MLI.
82	Turkmenistan*	Yes	PPT alone	N/A	N/A
83	Ukraine	Yes	PPT alone	N/A	N/A
84	United Arab Emirates	Yes	PPT alone	N/A	N/A
85	United Kingdom	Yes	PPT alone	N/A	N/A
86	Uruguay	No	N/A	Yes	N/A	MLI will enter into effect after 30 June 2020.
87	Uzbekistan*	No	N/A	Yes	N/A	Singapore has included this treaty to be covered by MLI. Treaty partner is not an IF member and has not signed MLI. (See Note 1)
88	Viet Nam	No	N/A	Yes	N/A	Singapore has included this treaty to be covered by MLI. However, treaty partner has not signed MLI.

Note: Discussion to incorporate BEPS MS in treaty is pending / on-going / concluded.