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HMRC internal manual

Double Taxation Relief Manual

Singapore: Treaty summary

The table summarises the provisions of the treaty as they relate to income beneficially owned by UK residents. The rate shown is the ‘treaty rate’ and does not reflect taxes chargeable under domestic law before relief is given under the provisions of the treaty. The ‘treaty rate’ is the maximum rate at which Singapore is permitted to tax income in the relevant categories under the treaty. Rates chargeable under domestic law may be higher or lower.

In all cases other conditions for relief (e.g. beneficial ownership) will have to be met before relief is due under the treaty. The text of the treaty itself should be consulted for the full details. The text of the treaty can be found on gov.uk.

Portfolio dividends 0% Article 10
     
Dividends on direct investments 0%   Article 10
Property income dividends 15%  Article 10
Interest 5% (note 1) Article 11
Royalties 8% Article 12
Government pensions Taxable only in Singapore unless the individual is a resident and a national of the UK Article 19
Other pensions Taxable only in the UK (includes annuities) (note 2) Article 18
Arbitration No Article 26

 

Note 1: Interest is exempt from tax in Singapore if the recipient is the beneficial owner and:

  • is the UK Government: this includes the Bank of England, the UK Export Credits Guarantee Department, CDC Group plc;
  • is a bank or similar financial institution; or
  • the interest is paid by a bank or similar financial institution.

Note 2: The individual must be subject to tax on that income in the UK.