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Second Protocol To Singapore-China DTA Ratified

by Mary Swire, Tax-New.com, Hong Kong

14 December 2009


A second protocol to the existing double taxation agreement (DTA) between Singapore and China entered into force on December 11, 2009.

The original agreement was signed on July 11, 2007, and became effective on January 1, 2008. The second protocol was signed on August 24, 2009, and, now that it has entered into force, its provisions shall take effect from January 1, 2010.

The major change in the new protocol relates to Article 22 of the original DTA regarding the elimination of double taxation on dividends. Where income is derived from a dividend paid by a company which is a resident of Singapore to a company which is a resident of China, and which owns not less than 20% (previously 10%) of the shares of the company paying the dividend, the tax credit in China shall take into account the tax paid in Singapore by the company paying the dividend in respect of its income.


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