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Consolidated text of relevant tax laws and related laws including comprehensive income tax treaties of Singapore.
This is the second part of a comprehensive two-part article, which addresses the manner in which, and the possible reasons why, Singapore adopted the principal purpose test (PPT) and the discretionary benefits provisions in the OECD's Multilateral Instrument, and the potential consequences of that decision. This part examines hypothetical consequences of the incorporation of the PPT and the discretionary benefits provision into Singapore's tax treaties. The author challenges certain aspects of mainstream scholarship, according to which the introduction of the PPT by offshore financial centres will most likely have a negative impact on efforts to attract foreign direct investment or otherwise jeopardize their business and tax competitive position. He concludes that Singapore's - and other jurisdictions with a similar approach to taxation of income - way of meeting the minimum standard under the OECD's BEPS Action 6 is quite bizarre: on the one hand, it may still allow highly mobile income to be channelled to tax havens and otherwise attract FDIs. On the other hand, it may allow the tax authorities of Singapore's tax treaty partners that are high-tax jurisdictions to deny benefits under their treaties with Singapore to arrangements or transactions with economic substance and non-tax business purpose.
This reporter is a complete and up-to-date collection of double tax agreements between Singapore and other countries.
This reporter is a complete and up-to-date collection of double tax agreements between Singapore and other countries.
This reporter is a complete and up-to-date collection of double tax agreements between Singapore and other countries.
A quick, handy and easy-to-use reference in navigating the various issues involving Singapore withholding tax and the application of double tax agreements. It is a compact handbook that is designed to help businesses make informed withholding tax decisions.
This comprehensive two-part article addresses the manner in which, and the possible reasons why, Singapore adopted the principal purpose test (PPT) and the discretionary benefits provisions in the OECD's Multilateral Instrument (MLI), and the potential consequences of that decision. Part 1 of the article focuses on the reasons for, and manner of, introducing the PPT while Part 2 examines the potential consequences, with specific reference to channelling highly mobile income to tax havens via Singapore. The author argues that Singapore's introduction of the PPT is unlikely to deter foreign direct investment and jeopardize the country's current attractive business and tax-competitive position. Rather, the way that Singapore introduced the PPT - by way of the MLI together with the discretionary benefits provision - appears to be in line with its policy of granting tax benefits (including treaty benefits) using the tax authority's broad discretionary powers and deploying a purposive approach to interpretation of the law.