Treaty coverage and residence
Singapore has comprehensive DTAs covering different income categories and limited agreements covering shipping or air transport income. Many provisions follow the OECD model, but individual treaties contain differences. A taxpayer claiming treaty protection generally needs a certificate of residence. The particular treaty, relevant income article and any applicable Multilateral Instrument modifications must therefore be checked together.
Resolving double taxation
Where taxation appears inconsistent with a DTA, the taxpayer may seek assistance under its MAP article. The guide explains MAP applications, the information IRAS expects, authorisation of representatives and the circumstances in which arbitration may be available. Treaty partners may interpret provisions differently, so the guide presents IRAS’s position rather than promising that every cross-border dispute will produce the same outcome.
Official source
A concise, independent Apex Gateway guide based on the official English source, not a reproduction of the complete document. Consult the original for full conditions, exceptions and subsequent updates.
Read the official PDF ↗