Entry into effect of the MLI. The effects of the MLI on this Agreement, as laid out in this Annex, shall have effect in Singapore: (a) for paragraph 4 of this Annex on the amendment of Article 24 (Mutual Agreement Procedure), for a case presented on or after 1 October 2019 without regard to the basis period to which the case relates. However, paragraph 4 of this Annex shall not apply to a case that was not eligible to be presented immediately before 1 October 2019. (b) for paragraph 5 of this Annex on the arbitration provisions, with respect to any tax paid, deemed paid or liable to be paid, before, on or after 1 October 2019. (c) for all other paragraphs in this Annex: (i) with respect to taxes withheld at source, in respect of amounts paid, deemed paid or liable to be paid (whichever is the earliest), on or after 1 January 2020; and (ii) with respect to taxes other than those withheld at source, where the income is derived or received in a basis period beginning on or after 1 April 2020. The Government of the Republic of Singapore and the Government of the Kingdom of Belgium, Desiring to amend the Agreement between the Government of the Republic of Singapore and the Government of the Kingdom of Belgium for the avoidance of double taxation and the prevention of fiscal evasion with respect to taxes on income signed at Singapore on 6 November 2006 (hereinafter referred to as “the Agreement”), Have agreed as follows: ARTICLE I The text of Article 25 of the Agreement is deleted and replaced by the following: 1. The competent authorities of the Contracting States shall exchange such information as is foreseeably relevant for carrying out the provisions of this Agreement or to the administration or enforcement of the domestic laws concerning taxes of every kind and description imposed by or on behalf of the Contracting States, insofar as the taxation thereunder is not contrary to the Agreement. The exchange of information is not restricted by Articles 1 and 2. 2. Any information received under paragraph 1 by a Contracting State shall be treated as secret in the same manner as information obtained under the domestic laws of that State and shall be disclosed only to persons or authorities (including courts and administrative bodies) concerned with the assessment or collection of, the enforcement or prosecution in respect of, the determination of appeals in relation to the taxes referred to in paragraph 1, or the oversight of the above. Such persons or authorities shall use the information only for such purposes. They may disclose the information in public court proceedings or in judicial decisions. 3. In no case shall the provisions of paragraphs 1 and 2 be construed so as to impose on a Contracting State the obligation: a) to carry out administrative measures at variance with the laws and administrative practice of that or of the other Contracting State; b) to supply information which is not obtainable under the laws or in the normal course of the administration of that or of the other Contracting State; c) to supply information which would disclose any trade, business, industrial, commercial or professional secret or trade process, or information, the disclosure of which would be contrary to public policy (ordre public). 4. If information is requested by a Contracting State in accordance with the provisions of this Article, the other Contracting State shall use its information gathering measures to obtain the requested information, even though that other State may not need such information for its own tax purposes. The obligation contained in the preceding sentence is subject to the limitations of paragraph 3 of this Article but in no case shall such limitations be construed to permit a Contracting State to decline to supply information solely because it has no domestic interest in such information. 5. In no case shall the provisions of paragraph 3 of this Article be construed to permit a Contracting State to decline to supply information solely because the information is held by a bank, other financial institution, nominee or person acting in an agency or a fiduciary capacity or because it relates to ownership interests in a person. In the case of Belgium, its tax administration shall have the power to ask for the disclosure of information and to conduct investigations and hearings notwithstanding any contrary provisions in its domestic tax laws.” ARTICLE II Belgium will notify Singapore, through diplomatic channels, of the completion of the procedures required by its law for the bringing into force of this Protocol. Upon such notification, when the necessary requirements for entry into force of this Protocol in Singapore have been complied with, Singapore shall notify Belgium through diplomatic channels. The Protocol shall enter into force 30 days after the date of notification made by Singapore to Belgium. The provisions of this Protocol shall have effect: a) in Belgium: (i) with respect to taxes due at source on income credited or payable on or after January 1 of the year next following the year in which the Protocol entered into force; (ii) with respect to other taxes charged on income of taxable periods beginning on or after January 1 of the year next following the year in which the Protocol entered into force; (iii) with respect to any other taxes imposed by or on behalf of Belgium due on or after January 1 of the year next following the year in which the Protocol entered into force; b) in Singapore: (i) in respect of tax chargeable on income for any year of assessment beginning on or after 1 January in the second calendar year following the year in which the Protocol enters into force; (ii) in respect of any other taxes imposed by or on behalf of Singapore due on or after 1 January of the year next following the year in which the Protocol entered into force. ARTICLE III This Protocol, which shall form an integral part of the Agreement, shall remain in force as long as the Agreement remains in force and shall apply as long as the Agreement itself is applicable.
Appears in 5 contracts
Sources: Double Taxation Agreement, Double Taxation Agreement, Double Taxation Agreement
Entry into effect of the MLI. The effects of the MLI on this Agreement, as laid out in this Annex, shall have effect in Singapore:
(a) subject to paragraph 12 of Article 25A, for paragraph 4 of this Annex on the amendment of Article 24 (Mutual Agreement Procedure), for a case presented on or after 1 October 2019 without regard to the basis period to which the case relates. However, paragraph 4 of this Annex shall not apply to a case that was not eligible to be presented immediately before 1 October 2019.
(b) for paragraph 5 3 of this Annex on the arbitration provisions, with respect to any tax paid, deemed paid or liable to be paid, before, on or after 1 October June 2019.;
(cb) for all other paragraphs in this Annex:
(i) with respect to taxes withheld at source, in respect of amounts paid, deemed paid or liable to be paid (whichever is the earliest), on or after 1 January 2020; and
(ii) with respect to taxes other than those withheld at source, where the income is derived or received in a basis period beginning on or after 1 April 2020December 2019. The Government of the Republic of Singapore and the Government of the Kingdom Republic of BelgiumFinland, Desiring to amend the Agreement between the Government of the Republic of Singapore and the Government Republic of the Kingdom of Belgium Finland for the avoidance of double taxation and the prevention of fiscal evasion with respect to taxes on income income, signed at Singapore on 6 November 2006 7 June 2002 (hereinafter referred to as “the Agreement”), Have agreed as follows:
ARTICLE I The text of Article 25 26 of the Agreement is deleted and replaced by the following:
1. The competent authorities of the Contracting States shall exchange such information as is foreseeably relevant for carrying out the provisions of this Agreement or to the administration or enforcement of the domestic laws concerning taxes of every kind and description imposed by or on behalf of the Contracting States, or of their political subdivisions or local authorities, insofar as the taxation thereunder is not contrary to the Agreement. The exchange of information is not restricted by Articles 1 and 2.
2. Any information received under paragraph 1 by a Contracting State shall be treated as secret in the same manner as information obtained under the domestic laws of that State and shall be disclosed only to persons or authorities (including courts and administrative bodies) concerned with the assessment or collection of, the enforcement or prosecution in respect of, the determination of appeals in relation to the taxes referred to in paragraph 1, or the oversight of the above. Such persons or authorities shall use the information only for such purposes. They may disclose the information in public court proceedings or in judicial decisions.
3. In no case shall the provisions of paragraphs 1 and 2 be construed so as to impose on a Contracting State the obligation:
a) to carry out administrative measures at variance with the laws and administrative practice of that or of the other Contracting State;
b) to supply information which is not obtainable under the laws or in the normal course of the administration of that or of the other Contracting State;
c) to supply information which would disclose any trade, business, industrial, commercial or professional secret or trade process, or information, the disclosure of which would be contrary to public policy (ordre public).
4. If information is requested by a Contracting State in accordance with the provisions of this Article, the other Contracting State shall use its information gathering measures to obtain the requested information, even though that other State may not need such information for its own tax purposes. The obligation contained in the preceding sentence is subject to the limitations of paragraph 3 of this Article but in no case shall such limitations be construed to permit a Contracting State to decline to supply information solely because it has no domestic interest in such information.
5. In no case shall the provisions of paragraph 3 of this Article be construed to permit a Contracting State to decline to supply information solely because the information is held by a bank, other financial institution, nominee or person acting in an agency or a fiduciary capacity or because it relates to ownership interests in a person. In the case of Belgium, its tax administration shall have the power to ask for the disclosure of information and to conduct investigations and hearings notwithstanding any contrary provisions in its domestic tax laws.”
ARTICLE II Belgium will Each of the Contracting States shall notify Singaporethe other, through diplomatic channels, of the completion of the procedures required by its law their respective laws for the bringing into force of this Protocol. Upon such notification, when the necessary requirements for entry into force of this Protocol in Singapore have been complied with, Singapore shall notify Belgium through diplomatic channels. The Protocol shall enter into force 30 days after the date of the later of such notification made by Singapore to Belgium. The provisions of this and the Protocol shall have effect:
a) in Belgium:
(i) with respect to taxes due at source effect on income credited or payable on or after January 1 of the year next following the year in which the Protocol entered into force;
(ii) with respect to other taxes charged on income of taxable periods beginning on or after January 1 of the year next following the year in which the Protocol entered into force;
(iii) with respect to any other taxes imposed by or on behalf of Belgium due on or after January 1 of the year next following the year in which the Protocol entered into force;
b) in Singapore:
(i) in respect of tax chargeable on income for any year of assessment beginning on or after 1 January in the second calendar year following the year in which the Protocol enters into force;
(ii) in respect of any other taxes imposed by or on behalf of Singapore due on or after 1 January of the year next following the year in which the Protocol entered into forcethat date.
ARTICLE III This Protocol, which shall form an integral part of the Agreement, shall remain in force as long as the Agreement remains in force and shall apply as long as the Agreement itself is applicable.
Appears in 4 contracts
Sources: Double Taxation Agreement, Double Taxation Agreement, Double Taxation Agreement
Entry into effect of the MLI. The effects of the MLI on this Agreement, as laid out in this Annex, shall have effect in Singapore:
(a) for paragraph 4 of this Annex on the amendment of Article 24 (Mutual Agreement Procedure), for a case presented on or after 1 October 2019 without regard to the basis period to which the case relates. However, paragraph 4 of this Annex shall not apply to a case that was not eligible to be presented immediately before 1 October 2019.
(b) for paragraph 5 of this Annex on the arbitration provisions, with respect to any tax paid, deemed paid or liable to be paid, before, on or after 1 October 2019.June 2020;
(cb) for all other paragraphs in this Annex:
(i) with respect to taxes withheld at source, in respect of amounts paid, deemed paid or liable to be paid (whichever is the earliest), on or after 1 January 20202021; and
(ii) with respect to taxes other than those withheld at source, where the income is derived or received in a basis period beginning on or after 1 April December 2020. The Government of the Republic of Singapore and the Government of the Kingdom of BelgiumPortuguese Republic, Desiring to amend the Agreement between the Government of the Republic of Singapore and the Government of the Kingdom of Belgium Portuguese Republic for the avoidance Avoidance of double taxation Double Taxation and the prevention Prevention of fiscal evasion Fiscal Evasion with respect Respect to taxes Taxes on income signed at Singapore on 6 November 2006 Income (hereinafter referred to as “the Agreement”’), Have agreed as follows:
ARTICLE I The text of Article 25 27 of the Agreement is deleted and replaced by the following:
1. The competent authorities of the Contracting States shall exchange such information as is foreseeably relevant for carrying out the provisions of this Agreement or to the administration or enforcement of the domestic laws concerning taxes of every kind and description imposed by or on behalf of the Contracting States, or of their political or administrative subdivisions or local authorities, insofar as the taxation thereunder is not contrary to the Agreement. The exchange of information is not restricted by Articles 1 and 2.
2. Any information received under paragraph 1 by a Contracting State shall be treated as secret in the same manner as information obtained under the domestic laws of that State and shall be disclosed only to persons or authorities (including courts and administrative bodies) concerned with the assessment or collection of, the enforcement or prosecution in respect of, the determination of appeals in relation to the taxes referred to in paragraph 1, or the oversight of the above. Such persons or authorities shall use the information only for such purposes. They may disclose the information in public court proceedings or in judicial decisions.
3. In no case shall the provisions of paragraphs 1 and 2 be construed so as to impose on a Contracting State the obligation:
(a) to carry out administrative measures at variance with the laws and administrative practice of that or of the other Contracting State;
(b) to supply information which is not obtainable under the laws or in the normal course of the administration of that or of the other Contracting State;
(c) to supply information which would disclose any trade, business, industrial, commercial or professional secret or trade process, or information, the disclosure of which would be contrary to public policy (ordre public).
4. If information is requested by a Contracting State in accordance with the provisions of this Article, the other Contracting State shall use its information gathering measures to obtain the requested information, even though that other State may not need such information for its own tax purposes. The obligation contained in the preceding sentence is subject to the limitations of paragraph 3 of this Article but in no case shall such limitations be construed to permit a Contracting State to decline to supply information solely because it has no domestic interest in such information.
5. In no case shall the provisions of paragraph 3 of this Article be construed to permit a Contracting State to decline to supply information solely because the information is held by a bank, other financial institution, nominee or person acting in an agency or a fiduciary capacity or because it relates to ownership interests in a person. In the case of Belgium, its tax administration shall have the power to ask for the disclosure of information and to conduct investigations and hearings notwithstanding any contrary provisions in its domestic tax laws.”
ARTICLE II Belgium will notify Singapore, through This Protocol shall enter into force on the thirtieth day after the date on which diplomatic channels, of notes indicating the completion of the internal legal procedures required by its law necessary in each Contracting State for the bringing into force of this Protocol. Upon such notification, when the necessary requirements for entry into force of this Protocol in Singapore have been complied with, Singapore shall notify Belgium through diplomatic channels. The Protocol shall enter into force 30 days after the date of notification made by Singapore to Belgium. The provisions of this Protocol shall have effect:
a) in Belgium:
(i) with respect to taxes due at source on income credited or payable on or after January 1 of the year next following the year in which the Protocol entered into force;
(ii) with respect to other taxes charged on income of taxable periods beginning on or after January 1 of the year next following the year in which the Protocol entered into force;
(iii) with respect to any other taxes imposed by or on behalf of Belgium due on or after January 1 of the year next following the year in which the Protocol entered into force;
b) in Singapore:
(i) in respect of tax chargeable on income for any year of assessment beginning on or after 1 January in the second calendar year following the year in which the Protocol enters into force;
(ii) in respect of any other taxes imposed by or on behalf of Singapore due on or after 1 January of the year next following the year in which the Protocol entered into forceexchanged.
ARTICLE III This Protocol, which Protocol shall form an integral part of the Agreement, Agreement and shall remain in force as long as the Agreement remains in force and shall apply as long as the Agreement itself is applicableforce.
Appears in 4 contracts
Sources: Double Taxation Agreement, Double Taxation Agreement, Double Taxation Agreement
Entry into effect of the MLI. The effects of the MLI on this Agreement, as laid out in this Annex, shall have effect in Singapore:
(a) for paragraph 4 of this Annex on the amendment of Article 24 (Mutual Agreement Procedure), for a case presented on or after 1 October 2019 without regard to the basis period to which the case relates. However, paragraph 4 of this Annex shall not apply to a case that was not eligible to be presented immediately before 1 October 2019.
(b) for paragraph 5 3 of this Annex on the arbitration provisions, with respect to any tax paid, deemed paid or liable to be paid, before, on or after 1 October April 2019.;
(cb) for all other paragraphs in this Annex:
(i) with respect to taxes withheld at source, in respect of amounts paid, deemed paid or liable to be paid (whichever is the earliest), on or after 1 January 2020; and
(ii) with respect to taxes other than those withheld at source, where the income is derived or received in a basis period beginning on or after 1 April 2020October 2019. The Government of the Republic of Singapore and the Government of the Kingdom of Belgium, Malta Desiring to amend the Agreement between the Government of the Republic of Singapore and the Government of the Kingdom of Belgium Malta for the avoidance of double taxation and the prevention of fiscal evasion with respect to taxes on income income, with Protocol, signed at Singapore on 6 November 21 March 2006 (hereinafter referred to as “the Agreement”), Have agreed as follows:
ARTICLE I The text of Article 25 (Exchange of Information) of the Agreement is deleted and replaced by the following:
1. The competent authorities of the Contracting States shall exchange such information as is foreseeably relevant for carrying out the provisions of this Agreement or to the administration or enforcement of the domestic laws concerning taxes of every kind and description imposed by or on behalf of the Contracting States, or of their political subdivisions or local authorities, insofar as the taxation thereunder is not contrary to the Agreement. The exchange of information is not restricted by Articles 1 and 2.
2. Any information received under paragraph 1 by a Contracting State shall be treated as secret in the same manner as information obtained under the domestic laws of that State and shall be disclosed only to persons or authorities (including courts and administrative bodies) concerned with the assessment or collection of, the enforcement or prosecution in respect of, the determination of appeals in relation to the taxes referred to in paragraph 1, or the oversight of the above. Such persons or authorities shall use the information only for such purposes. They may disclose the information in public court proceedings or in judicial decisions.
3. In no case shall the provisions of paragraphs 1 and 2 be construed so as to impose on a Contracting State the obligation:
a) to carry out administrative measures at variance with the laws and administrative practice of that or of the other Contracting State;
b) to supply information which is not obtainable under the laws or in the normal course of the administration of that or of the other Contracting State;
c) to supply information which would disclose any trade, business, industrial, commercial or professional secret or trade process, or information, the disclosure of which would be contrary to public policy (ordre public).
4. If information is requested by a Contracting State in accordance with the provisions of this Article, the other Contracting State shall use its information gathering measures to obtain the requested information, even though that other State may not need such information for its own tax purposes. The obligation contained in the preceding sentence is subject to the limitations of paragraph 3 of this Article but in no case shall such limitations be construed to permit a Contracting State to decline to supply information solely because it has no domestic interest in such information.
5. In no case shall the provisions of paragraph 3 of this Article be construed to permit a Contracting State to decline to supply information solely because the information is held by a bank, other financial institution, nominee or person acting in an agency or a fiduciary capacity or because it relates to ownership interests in a person. In the case of Belgium, its tax administration shall have the power to ask for the disclosure of information and to conduct investigations and hearings notwithstanding any contrary provisions in its domestic tax laws.”
ARTICLE II Belgium will Each of the Contracting States shall notify Singaporethe other, through diplomatic channels, of the completion of the procedures required by its law their respective laws for the bringing into force of this Protocol. Upon such notification, when the necessary requirements for entry into force of this Protocol in Singapore have been complied with, Singapore shall notify Belgium through diplomatic channels. The Protocol shall enter into force 30 days after the date of notification made by Singapore to Belgium. The provisions the later of this Protocol shall have effect:
a) in Belgium:
(i) with respect to taxes due at source on income credited or payable on or after January 1 of the year next following the year in which the Protocol entered into force;
(ii) with respect to other taxes charged on income of taxable periods beginning on or after January 1 of the year next following the year in which the Protocol entered into force;
(iii) with respect to any other taxes imposed by or on behalf of Belgium due on or after January 1 of the year next following the year in which the Protocol entered into force;
b) in Singapore:
(i) in respect of tax chargeable on income for any year of assessment beginning on or after 1 January in the second calendar year following the year in which the Protocol enters into force;
(ii) in respect of any other taxes imposed by or on behalf of Singapore due on or after 1 January of the year next following the year in which the Protocol entered into forcesuch notification.
ARTICLE III This Protocol, which shall form an integral part of the Agreement, shall remain in force as long as the Agreement remains in force and shall apply as long as the Agreement itself is applicable.
Appears in 3 contracts
Sources: Double Taxation Agreement, Double Taxation Agreement, Double Taxation Agreement
Entry into effect of the MLI. The effects of the MLI on this Agreement, as laid out in this Annex, shall have effect in Singapore:
(a) for paragraph 4 of this Annex on the amendment of Article 24 (Mutual Agreement Procedure), for a case presented on or after 1 October 2019 without regard to the basis period to which the case relates. However, paragraph 4 of this Annex shall not apply to a case that was not eligible to be presented immediately before 1 October 2019.
(b) for paragraph 5 of this Annex on the arbitration provisions, with respect to any tax paid, deemed paid or liable to be paid, before, on or after 1 October 2019.
(c) for all other paragraphs in this Annex:
(i) with respect to taxes withheld at source, in respect of amounts paid, deemed paid or liable to be paid (whichever is the earliest), on or after 1 January 20202024; and
(iib) with respect to taxes other than those withheld at source, where the income is derived or received in a basis period beginning on or after 1 April 2020January 2024. The Government of the Republic of Singapore and the Government of the Kingdom of BelgiumUnited Mexican States, Desiring to amend the Agreement between the Government of the Republic of Singapore and the Government of the Kingdom of Belgium United Mexican States for the avoidance of double taxation and the prevention of fiscal evasion with respect to taxes on income income, signed at Singapore on 6 9 November 2006 1994 (hereinafter referred to as “the Agreement”), Have agreed as follows:
ARTICLE I The text of Article 25 26 of the Agreement is deleted and replaced by the following:
1. The competent authorities of the Contracting States shall exchange such information as is foreseeably relevant for carrying out the provisions of this Agreement or to the administration or enforcement of the domestic laws concerning taxes of every kind and description imposed by or on behalf of the Contracting States, or of their political subdivisions or local authorities, insofar as the taxation thereunder is not contrary to the Agreement. The exchange of information is not restricted by Articles 1 and 2.
2. Any information received under paragraph 1 by a Contracting State shall be treated as secret in the same manner as information obtained under the domestic laws of that State and shall be disclosed only to persons or authorities (including courts and administrative bodies) concerned with the assessment or collection of, the enforcement or prosecution in respect of, the determination of appeals in relation to the taxes referred to in paragraph 1, or the oversight of the above. Such persons or authorities shall use the information only for such purposes. They may disclose the information in public court proceedings or in judicial decisions.
3. In no case shall the provisions of paragraphs 1 and 2 be construed so as to impose on a Contracting State the obligation:
a) to carry out administrative measures at variance with the laws and administrative practice of that or of the other Contracting State;
b) to supply information which is not obtainable under the laws or in the normal course of the administration of that or of the other Contracting State;
c) to supply information which would disclose any trade, business, industrial, commercial or professional secret or trade process, or information, the disclosure of which would be contrary to public policy (ordre public).
4. If information is requested by a Contracting State in accordance with the provisions of this Article, the other Contracting State shall use its information gathering measures to obtain the requested information, even though that other State may not need such information for its own tax purposes. The obligation contained in the preceding sentence is subject to the limitations of paragraph 3 of this Article but in no case shall such limitations be construed to permit a Contracting State to decline to supply information solely because it has no domestic interest in such information.
5. In no case shall the provisions of paragraph 3 of this Article be construed to permit a Contracting State to decline to supply information solely because the information is held by a bank, other financial institution, nominee or person acting in an agency or a fiduciary capacity or because it relates to ownership interests in a person. In the case of Belgium, its tax administration shall have the power to ask for the disclosure of information and to conduct investigations and hearings notwithstanding any contrary provisions in its domestic tax laws.”
ARTICLE II Belgium will The Contracting States shall notify Singaporeeach other in writing, through diplomatic channels, of the completion of that the procedures required by its law legislation for the bringing into force of this Protocol. Upon such notification, when the necessary requirements for entry into force of this Protocol in Singapore have been complied with, Singapore shall notify Belgium through diplomatic channelssatisfied. The Protocol shall enter into force 30 thirty (30) days after the date of notification made by Singapore receipt to Belgiumthe later of such notifications. The provisions of this Protocol shall have effect:
a) in Belgium:
(i) with respect to taxes due at source on income credited or payable on or after effect from 1 January 1 of the calendar year next following the year in which the Protocol entered into force;
(ii) with respect to other taxes charged on income of taxable periods beginning on or after January 1 of the year next following the year in which the Protocol entered entry into force;
(iii) with respect to any other taxes imposed by or on behalf force of Belgium due on or after January 1 of the year next following the year in which the Protocol entered into force;
b) in Singapore:
(i) in respect of tax chargeable on income for any year of assessment beginning on or after 1 January in the second calendar year following the year in which the Protocol enters into force;
(ii) in respect of any other taxes imposed by or on behalf of Singapore due on or after 1 January of the year next following the year in which the Protocol entered into forcethis Protocol.
ARTICLE III This Protocol, which shall form an integral part of the Agreement, shall remain in force as long as the Agreement remains in force and shall apply as long as the Agreement itself is applicable.
Appears in 1 contract
Sources: Double Taxation Agreement
Entry into effect of the MLI. The effects of the MLI on this Agreement, as laid out in this Annex, shall have effect in Singapore:
(a) for paragraph 4 of this Annex on the amendment of Article 24 (Mutual Agreement Procedure), for a case presented on or after 1 October 2019 without regard to the basis period to which the case relates. However, paragraph 4 of this Annex shall not apply to a case that was not eligible to be presented immediately before 1 October 2019.
(b) for paragraph 5 of this Annex on the arbitration provisions, with respect to any tax paid, deemed paid or liable to be paid, before, on or after 1 October 2019.
(c) for all other paragraphs in this Annex:
(i) with respect to taxes withheld at source, in respect of amounts paid, deemed paid or liable to be paid (whichever is the earliest), on or after 1 January 20202023; and
(iib) with respect to taxes other than those withheld at source, where the income is derived or received in a basis period beginning on or after 1 April 2020March 2023. The Government of the Republic of Singapore and the Government of the Kingdom People’s Republic of BelgiumChina, Desiring Having regard to amend the Agreement between the Government of the Republic of Singapore and the Government of the Kingdom People’s Republic of Belgium China for the avoidance Avoidance of double taxation Double Taxation and the prevention Prevention of fiscal evasion Fiscal Evasion with respect to taxes Taxes on income Income, signed at Singapore on 6 November 2006 11th day of July 2007 (hereinafter referred to as “the Agreement”), Have agreed as followsthat the following provisions shall form an integral part of the Agreement:
ARTICLE I The text of Article 1 With respect to Article 25 of the Agreement is Agreement, paragraphs 1, 2 and 3 shall be deleted and replaced by the following:
1. The competent authorities of the Contracting States shall exchange such information as is foreseeably relevant for carrying out the provisions of this Agreement or to the administration or enforcement of the domestic laws concerning taxes of every kind and description imposed by or on behalf of the Contracting StatesStates or local authorities, insofar as the taxation thereunder is not contrary to the Agreement. The exchange of information is not restricted by Articles 1 and 2.
2. Any information received under paragraph 1 by a Contracting State shall be treated as secret in the same manner as information obtained under the domestic laws of that State and shall be disclosed only to persons or authorities (including courts and administrative bodies) concerned with the assessment or collection of, the enforcement or prosecution in respect of, the determination of appeals in relation to the taxes referred to in paragraph 1, or the oversight of the above. Such persons or authorities shall use the information only for such purposes. They may disclose the information in public court proceedings or in judicial decisions.
3. In no case shall the provisions of paragraphs 1 and 2 be construed so as to impose on a Contracting State the obligation:
(a) to carry out administrative measures at variance with the laws and administrative practice of that or of the other Contracting State;
(b) to supply information which is not obtainable under the laws or in the normal course of the administration of that or of the other Contracting State;
(c) to supply information which would disclose any trade, business, industrial, commercial or professional secret or trade process, or information, the disclosure of which would be contrary to public policy (ordre public).
4. If information is requested by a Contracting State in accordance with the provisions of this Article, the other Contracting State shall use its information gathering measures to obtain the requested information, even though that other State may not need such information for its own tax purposes. The obligation contained in the preceding sentence is subject to the limitations of paragraph 3 of this Article but in no case shall such limitations be construed to permit a Contracting State to decline to supply information solely because it has no domestic interest in such information.
5. In no case shall the provisions of paragraph 3 of this Article be construed to permit a Contracting State to decline to supply information solely because the information is held by a bank, other financial institution, nominee or person acting in an agency or a fiduciary capacity or because it relates to ownership interests in a person. In the case of Belgium, its tax administration shall have the power to ask for the disclosure of information and to conduct investigations and hearings notwithstanding any contrary provisions in its domestic tax laws.”
ARTICLE II Belgium will Article 2 The Contracting States shall notify Singapore, each other through diplomatic channels, of the completion of channels that the procedures required by its law laws for the bringing into force of this Protocol. Upon such notification, when the necessary requirements for entry into force of this Third Protocol in Singapore have been complied with, Singapore shall notify Belgium through diplomatic channels. The This Third Protocol shall enter into force 30 days after on the date of notification made by Singapore to Belgiumthe receipt of the later notification. The provisions of this Third Protocol shall have effect:
a) effect in Belgium:
(i) with respect of taxes relating to taxes due at source on income credited or payable on or after January 1 of the year next following the year in which the Protocol entered into force;
(ii) with respect to other taxes charged on income of taxable periods beginning on or after January 1 of the year next following the year in which the Protocol entered into force;
(iii) with respect to any other taxes imposed by or on behalf of Belgium due on or after January 1 of the year next following the year in which the Protocol entered into force;
b) in Singapore:
(i) in respect of tax chargeable on income for any year of assessment beginning on or after 1 January in the second calendar year following the year in which the Protocol enters into force;
(ii) in respect of any other taxes imposed by or on behalf of Singapore due on or after 1 January of the calendar year next following the year of the entry into force of this Third Protocol. IN WITNESS WHEREOF the undersigned, duly authorized thereto, have signed this Protocol. DONE at Beijing on this 23rd day of July, 2010 in which duplicate, in the Protocol entered into force.
ARTICLE III This ProtocolChinese and English languages, which both texts being equally authentic. The Government of the People’s Republic of China and the Government of the Republic of Singapore, Having regard to the Agreement between the Government of the People’s Republic of China and the Government of the Republic of Singapore for the Avoidance of Double Taxation and the Prevention of Fiscal Evasion with respect to Taxes on Income, signed at Singapore on 11th day of July 2007 (hereinafter referred to as "the Agreement"), Have agreed that the following provisions shall form an integral part of the Agreement:
Article 1 With respect to Article 5 of the Agreement: In respect of paragraph 3 (b), the term “6 months” shall remain in force as long as be deleted and replaced by “183 days”.
Article 2 With respect to Article 11 of the Agreement remains in force Agreement:
1. Paragraph 3 shall be deleted and shall apply as long as replaced by the Agreement itself is applicable.following:
Appears in 1 contract