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HMRC internal manual

Double Taxation Relief Manual

Singapore: Interest and Royalties

Under the agreement, interest and royalties arising in Singapore and paid to a resident of the United Kingdom who is the beneficial owner of the income are taxable in Singapore at a rate not exceeding 15 per cent if they arise or accrue on or before 31 December 1999; and at a rate not exceeding 10 per cent if they arise or accrue after that date (Article 11(2) and Article 12(2)).

Where however the interest or royalty is effectively connected (see INTM153110) with a permanent establishment or fixed base which the United Kingdom resident recipient has in Singapore the provisions of the Business profits Article (Article 7) or the Independent personal services Article (Article 14) will apply.

However, interest arising in Singapore is exempt from tax in Singapore if it is paid to the United Kingdom government, the Bank of England, the Export Credits Guarantee Department or the Commonwealth Development Corporation.