Switzerland and Singapore have signed their first double taxation agreement (DTA) in 1975 and at the beginning of 2011 it was renewed. The new double taxation treaty Switzerland signed with Singapore contains provisions with respect to the avoidance of double taxation of the income tax. The new agreement was ratified in 2012 and enforced at the beginning of 2013. The agreement applies to both Singapore and Swiss companies and citizens.
The double tax agreement covers all the taxes on income imposed by the federal and local authorities of both contracting states. The Singapore or Swiss income taxes governed by the DTA are levied on the total income or other incomes, such a capital gains taxes or property taxes. The tax covered by the agreement in Singapore is the income tax, while in the case of Switzerland the agreement applies on:
A particularity of the Switzerland-Singapore double tax treaty is that the agreement does not cover taxes applied to lottery prizes. These taxes will be levied at source in the resident’s country of origin. However, the agreement will cover similar taxes such as interests, dividends or royalties. The countries are also required to notify each other about any changes brought to their taxation systems.
The taxes applied to the dividends paid by a Swiss company in Singapore and the other way around will be levied at a 5% rate of the gross amount of the dividends, if the beneficial owner of the dividends holds at least 10% of the voting power in the company paying the dividends, and 15% in all other cases. Interests will be taxed with 5% in both contracting states. Capital gains resulted from the sale of immovable property in Switzerland or in Singapore by a resident of one the contracting parties may be taxed in the other state. Other incomes, such as employment salaries or benefits will only be taxed at source in the country where the employment services are rendered.
For complete information about the provisions of the double taxation treaty with Singapore you may contact our law firm in Switzerland.
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