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HMRC internal manual

Double Taxation Relief Manual

Singapore: Tax Spared

Although the agreement provides for credit to be given for tax `spared’ (see INTM161270 and INTM161280) in Singapore under the provisions of Singapore law expressly set out in Article 23(4), the period in which such tax sparing was available has now expired.

Relief from United Kingdom tax is not available where the profits or income on which tax is spared arise or accrue after 31 December 2001.

The agreement also provided that, for periods prior to 31 December 2001, tax sparing was not available for a period beginning more than ten years after tax was first spared in respect of the source in question, whether that period began before or after the agreement entered into force.

All amounts of tax spared for which credit relief is given should be reported to HMRC, Business International, Tax Treaty Team, as mentioned in INTM161290.