INDIA SINGAPORE DTAA PDF

View: Go for nuanced tweaking of taxes, not outright tax holiday. What is an income-tax tax slab? Government identifies sectors for tax sops. All rights reserved. For reprint rights: Times Syndication Service. Politics and Nation.

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View: Go for nuanced tweaking of taxes, not outright tax holiday. What is an income-tax tax slab? Government identifies sectors for tax sops. All rights reserved. For reprint rights: Times Syndication Service.

Politics and Nation. Defence Defence National International Industry. Company Corporate Trends Deals. International Business World News. Market Watch. Pinterest Reddit. Besides Singapore, India amended bilateral tax treaties with Mauritius and Cyprus in India had amended the tax treaty with Singapore on December 30, , under which for two years beginning April 1, , capital gains tax will be imposed at 50 per cent of the prevailing domestic rate.

Full rate will apply from April 1, The revision of tax treaty will help curb revenue loss, prevent double non-taxation and streamline the flow of investments, a finance ministry statement said, adding that the amended tax treaty has been notified.

The tax treaty amendment provides for source-based taxation of capital gains arising on sale of shares in a company with effect from April 1, , it said. The amended treaty also inserts Article 9 2 in the DTAA, which will facilitate relieving of economic double taxation in transfer pricing cases. It also allows application of domestic law and measures concerning prevention of tax avoidance or evasion.

As per the amended Mauritius tax treaty, companies have to pay short-term capital gains tax at half the rate prevailing during the two-year transition period. The full rate will kick in from April 1, Short-term capital gain tax is levied at 15 per cent in India while long-term capital gain tax is zero. Read more on Tax. Mutual Agreement Procedure. Add Your Comments. Follow us on. Download et app.

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Limitation of Benefits clause in the India Singapore DTAA - An analysis of recent decisions

An examination of the breakdown of these inflows of FDI into India by source country reveals that the combination of Mauritius, Cyprus, Singapore and Netherlands constitute about 60 per cent of overall FDI equity inflows on a cumulative basis over the period to In , Singapore surpassed Mauritius as the single largest source of FDI into India, with almost 35 per cent of FDI equity inflows into India originating from Singapore as against just over 20 percent from Mauritius. All the four countries mentioned above impose very low-to-negligible capital gains taxes domestically and have in place Double Taxation Avoidance Agreements DTAAs with India. The DTAAs have traditionally implied that there will be exemptions to capital gains taxes for investments from these countries which in turn have facilitated their role as important sources of FDI into India. However, over the years, the DTAAs have also given rise to widespread concerns in India that they may have been misused by several Indian companies and individuals to avoid domestic taxation and instead engage in round-tripping of funds back to India or trans-shipping of funds from third countries, not unlike what was done historically in Hong Kong vis-a-vis China.

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The Singapore-India Double Tax Treaty

Please contact customerservices lexology. As per that Article if the exemption under the treaty is qua an income which is taxable in other state only on receipt of income in that state then the exemption shall be allowed only when remittance of such income has been made. The dispute in this case really centered around whether the income in question was taxable in Singapore on receipt basis or on accrual basis. India, the provisions of Article 24 restrict exemption of such capital gains to the extent of repatriation of such income to the other country i. In fact, there was no such repatriation of said income reflected in the bank statement furnished.

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