On September 1, 2022 the amendments made by the Multilateral Convention to Implement Tax Treaty Related Measures to Prevent Base Erosion and Profit Shifting (the MLI) to the Agreement between the Government of the Republic of Singapore and the Government of the People’s Republic of China for the avoidance of double taxation and the prevention of fiscal evasion with respect to taxes on income (the DTA) took effect on September 1, 2022.


Details of the amendments the MLI makes to the DTA can be found in Annex A to the DTA as published on the website of the Inland Revenue Authority of Singapore.


The amendments include a.o.:

  • An adjustment to the appropriate adjustment clause as laid down in Article 9, Paragraph 2 of the DTA. 
  • A deletion of the separate principal purpose tests that were laid down in the Articles 10 (DIVIDENDS), 11 (INTEREST) and 12 (ROYALTIES) of the DTA and replacing them by a new anti-abuse rule containing the principle purpose test that is laid down in the newly to be inserted Article 27a (PREVENTION OF TREATY ABUSE).

The text of the DTA and the effects of the MLI on the DTA (See Annex A, which starts on page 21 of the document) can be found here on the website of the Inland Revenue Authority of Singapore.



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