🇸🇬 India–Singapore DTAA
India–Singapore tax treaty
Signed 1994 · notified 1994 (revised 2005, 2011, 2016). A practitioner's reference, not legal advice — confirm positions against current text and protocols before acting.
Highlights
- ·2016 protocol aligned with Mauritius — source-based taxation of capital gains from 1 Apr 2017
- ·LOB (limitation of benefits) test mandatory for treaty access
- ·Active substance test: ≥ S$200,000 expenditure in prior 24 months
Withholding rates
| Income | Treaty rate | Domestic rate | Note |
|---|---|---|---|
| Dividends | 10% / 15% | 20% | — |
| Interest | 10% / 15% | 20% | — |
| Royalties / FTS | 10% | 10% | — |
| Capital gains (shares) | Per domestic law | Per s.111A / 112A | — |
Treaty rate available only on furnishing TRC, Form 10F and beneficial-owner declaration. PPT / GAAR / LOB tests may further restrict access.
Permanent establishment
Fixed place; services PE > 90 days; construction > 183 days.
Residency tie-breaker
OECD-model.
FTC mechanism
India: Form 67. Singapore: unilateral and treaty FTC.
Common use cases
- ✓Indian startups with Singapore holding company — flip structures
- ✓Singapore PE / VC funds investing into India
- ✓Singapore resident employees on India assignments
Pitfalls we see
- !Shell company test under LOB — needs operating substance
- !GAAR + PPT can deny benefits even with valid TRC
Have an India–Singapore fact pattern?
We give a one-page written position with treaty cites and FTC computation, usually within 3 working days.
Request a written position