08 January 2016

Luxembourg - Singapore revised Income Tax Treaty and Protocol enter into force

The Luxembourg - Singapore revised Income Tax Treaty (Revised Treaty) and the protocol (Protocol) entered into force on December 28, 2015, replacing the earlier treaty signed on March 6, 1993 (1993 Treaty). In addition to updates to the wording to align with changes in the Organization for Economic Co-operation and Development (OECD) Model Tax Convention, the highlights of the Revised Treaty include but are not limited to: exclusive resident country taxation on dividends, interest and shipping and air transport profits; changes to the permanent establishment (PE) definition; a reduction of the withholding tax rate on royalties and the removal of limitation of relief clause.

A Tax Alert prepared by Ernst & Young's Luxembourg Tax Desk in New York, and attached below, provides additional details.

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Document ID: 2016-0042