28 December 2016 Protocol to amend Singapore and Russia income tax treaty enters into force The Protocol (the Protocol) to amend the existing tax treaty (the Treaty) between Singapore and Russia entered into force on November 25. The Protocol introduces a number of important changes to the Treaty including: (i) a specific limitation of benefits clause based on a main purpose test for dividends, interest and royalties; (ii) a longer threshold period for determining the presence of a permanent establishment (PE); and (iii) reduced withholding tax rates for interest and royalties. A Tax Alert prepared by EY's Global Tax Desk Network, and attached below, provides additional details. Document ID: 2016-2231 |