Singapore, Germany Add BEPS Amendments To DTA

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

16 December 2019

Singapore and Germany have signed a protocol to their double taxation agreement, which brings the treaty into line with international standards and amends the maximum withholding tax rates that may be charged.

The DTA dates from 2004. The protocol was signed on December 9, 2019.

The protocol reduces the maximum withholding tax rate that can be charged in the source country for cross-border dividends income from 15 percent to 10 percent. The reduced rate of five percent for qualifying participations of more than 10 percent in the paying company will remain the same.

The protocol also reduces the withholding tax rate on interest from eight percent to zero, and lowers the rate on royalties from eight percent to five percent.

The protocol incorporates into the DTA the internationally agreed minimum standards to counter treaty abuse. It amends the exchange of information provisions in line with international standards on the exchange of information on request. It also updates the Mutual Agreement Procedure (MAP) article to provide a mechanism that will allow taxpayers to request arbitration in eligible MAP cases that have not been resolved between the competent authorities of Singapore and Germany in three years.

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