As reported in Singapore’s stage 2 peer review report published in October 2020, Singapore had 93 tax treaties of which 87 were in force and 6 (Armenia, Brazil, Gabon, Greece, Kenya and Turkmenistan) not yet in force. Of the 93 tax treaties, 83 contained a MAP provision that is in line with or will be modified by the Multilateral Instrument to be in line the Action 14 Minimum Standard.
As of 15 August 2023, Singapore has 96 tax treaties of which 93 are in force and 3 (Gabon, Kenya, and Cabo Verde) not yet in force. Of the 96 tax treaties, 88 contained a MAP provision that is in line with or will be modified by the Multilateral Instrument to be in line with the Action 14 Minimum Standard. Singapore has already initiated negotiations or is in contact with the treaty partners of the remaining 8 tax treaties to initiate renegotiation of the tax treaties to be in line with the Action 14 Minimum Standard.
Making Dispute Resolution Mechanisms More Effective – Consolidated Information on Mutual Agreement Procedures 2023
Singapore
Recent developments relating to MAP in Singapore prior to 15 August 2023
Developments relating to MAP in the tax treaty network
Other developments relating to MAP
In October 2021, Singapore updated its e-Tax Guide on Avoidance of Double Taxation Agreements (https://www.iras.gov.sg/media/docs/) to provide guidance on arbitration provisions found in Singapore’s tax treaties.
Latest Action 14 Peer Review report
22 October 2020 - https://doi.org/10.1787/3d152880-en
Tax treaty network of Singapore
96 treaties, applicable to 96 jurisdictions (covering all treaties signed, although not necessarily in force)
status of MLI: in force.
Table 1. State of play of Singapore's tax treaty network
Source: OECD
Singapore's MAP programme
Organisation of competent authority function
21 persons:
four Competent Authorities for MAP
11 staff handling attribution/allocation MAP cases (and other areas relating to cross border transfer pricing matters)
six staff handling other MAP cases (and other areas relating to tax treaty matters).
contact persons for MAP requests:
please refer to https://www.iras.gov.sg/taxes/international-tax
the MAP application may also be submitted electronically via: https://mytax.iras.gov.sg.
Figure 1. Competent Authority Organisational Structure
Source: OECD
Table 2. Guidance on the MAP process
Overview of Singapore's MAP Statistics for 2022
Please refer to https://www.oecd.org/tax/dispute/map-statistics-singapore.pdf for details with respect to Singapore's MAP Statistics.
Figure 2. Cases Closed in 2022
Source: OECD
Figure 3. Evolution of Singapore's MAP caseload (2016-22)
Source: OECD
Table 3. Overview of Singapore’s MAP caseload for 2022
Source: OECD
Table 4. Singapore’s average time to resolve MAP cases in 2022
Source: OECD