Base Erosion and Profit Shifting: International Convention to Implement Tax Treaty Related Measures

base-erosion-and-profit-shifting

Singapore took part in the MLI negotiations as part of its commitment to enact the minimal requirement for preventing treaty misuse. The MLI is designed to make it possible for jurisdictions to quickly update their tax treaties in order to put Base Erosion and Profit Shifting (BEPS) recommendations relevant to tax treaties into effect. The MLI also enhances the conflict resolution processes.

Date	What’s new
5 April 2023	This day saw the implementation of the MLI’s modifications to Singapore’s DTA with Romania. You may read more about these changes on IRAS’s DTA listing page.
1 January 2023	This day saw the implementation of the MLI’s modifications to Singapore’s DTA with Bulgaria and South Africa. You may read more about these changes on IRAS’s listing page.
1 September 2022	This day saw the implementation of the MLI’s modifications to Singapore’s DTA with China. You may read more about these changes on IRAS’s DTA listing page.
1 July 2022	This day saw the implementation of the MLI’s modifications to Singapore’s DTA with Spain and Thailand. You may read more about these changes on IRAS’s DTA listing page.
1 June 2022	This day saw the implementation of the MLI’s modifications to Singapore’s DTA with Bahrain. You may read more about these changes on IRAS’s DTA listing page.
1 April 2022	This day saw the implementation of the MLI’s modifications to Singapore’s DTA with Seychelles. You may read more about these changes on IRAS’s DTA listing page.
1 July 2021	This day saw the implementation of the MLI’s modifications to Singapore’s DTA with Hungary. You may read more about these changes on IRAS’s DTA listing page.
1 June 2021	This day saw the implementation of the MLI’s modifications to Singapore’s DTA with Malaysia. You may read more about these changes on IRAS’s DTA listing page.
1 April 2021	This day saw the implementation of the MLI’s modifications to Singapore’s DTA with Barbados and Pakistan. You may read more about these changes on IRAS’s DTA listing page.
1 March 2021	This day saw the implementation of the MLI’s modifications to Singapore’s DTA with Panama. You may read more about these changes on IRAS’s DTA listing page.
1 January 2021	This day saw the implementation of the MLI’s modifications to Singapore’s DTA with Albania and Egypt. You may read more about these changes on IRAS’s DTA listing page
26 December 2020	This day saw the implementation of the MLI’s modifications to Singapore’s DTA with Indonesia. You may read more about these changes on IRAS’s DTA listing page.
1 November 2020	This day saw the implementation of the MLI’s modifications to Singapore’s DTA with Oman. You may read more about these changes on IRAS’s DTA listing page.
1 October 2020	This day saw the implementation of the MLI’s modifications to Singapore’s DTA with Kazakhstan. You may read more about these changes on IRAS’s DTA listing page.
1 September 2020	This day saw the implementation of the MLI’s modifications to Singapore’s DTA with Czech Republic. You may read more about these changes on IRAS’s DTA listing page.
1 July 2020	This day saw the implementation of the MLI’s modifications to Singapore’s DTA with Czech Republic. You may read more about these changes on IRAS’s DTA listing page.
1 June 2020	This day saw the implementation of the MLI’s modifications to Singapore’s DTA with Portugal and Uruguay. You may read more about these changes on IRAS’s DTA listing page.
30 May 2020	This day saw the implementation of the MLI’s modifications to Singapore’s DTA with Russia. You may read more about these changes on IRAS’s DTA listing page.
1 May 2020	This day saw the implementation of the MLI’s modifications to Singapore’s DTA with Cyprus and Saudi Arabia . You may read more about these changes on IRAS’s DTA listing page.
1 April 2020	This day saw the implementation of the MLI’s modifications to Singapore’s DTA with Liechtenstein and Qatar . You may read more about these changes on IRAS’s DTA listing page.
1 February 2020	This day saw the implementation of the MLI’s modifications to Singapore’s DTA with Latvia and Mauritius . You may read more about these changes on IRAS’s DTA listing page.
1 January 2020	This day saw the implementation of the MLI’s modifications to Singapore’s DTA with Denmark . You may read more about these changes on IRAS’s DTA listing page.
1 December 2019	This day saw the implementation of the MLI’s modifications to Singapore’s DTA with Canada and Ukraines . You may read more about these changes on IRAS’s DTA listing page.
1 October 2019	This day saw the implementation of the MLI’s modifications to Singapore’s DTA with Belgium and India . You may read more about these changes on IRAS’s DTA listing page.
1 September 2019	This day saw the implementation of the MLI’s modifications to Singapore’s DTA with United Arab Emirates . You may read more about these changes on IRAS’s DTA listing page.
1 August 2019	This day saw the implementation of the MLI’s modifications to Singapore’s DTA with Luxembourg . You may read more about these changes on IRAS’s DTA listing page.
1 July 2019	This day saw the implementation of the MLI’s modifications to Singapore’s DTA with Georgia and the Netherlands . You may read more about these changes on IRAS’s DTA listing page.
1 June 2019	This day saw the implementation of the MLI’s modifications to Singapore’s DTA with Finland and Guernsey . You may read more about these changes on IRAS’s DTA listing page.
1 May 2019	This day saw the implementation of the MLI’s modifications to Singapore’s DTA with Ireland . You may read more about these changes on IRAS’s DTA listing page.
1 April 2019	The MLI became effective for Singapore. This day saw the implementation of the MLI’s modifications to Singapore’s DTAs with the UK, Australia, France, Isle of Man, Israel, Japan, Jersey, Lithuania, Malta, New Zealand, and the Slovak Republic. You may read more about these changes on IRAS’s DTA Listing page.
21 December 2018	Singapore submitted their ratification document for the MLI. Singapore’s MLI will take effect on April 1st, 2019. Read the press release.
1 July 2018	The MLI entered into force after the deposit of instruments of ratification by five jurisdictions.
7 June 2017	Singapore submitted their ratification document for the MLI. Singapore’s MLI will take effect on April 1st, 2019. Read the press release.
24 November 2016 (Paris time)	The MLI negotiations were finished by more than 100 countries, including Singapore. Read more on the text of the MLI (PDF, 277KB) and the explanatory statement to the MLI (PDF, 557KB).

Interaction between the MLI and tax agreements

The list of DTAs that Singapore plans to modify using the MLI at the time of ratification of the MLI on 21 December 2018 may be viewed at this link (PDF, 135KB). Only if Singapore’s treaty partners opt to revise the DTAs via the MLI will these DTAs be changed. Under the MLI, DTAs that will be modified by it are referred to as Covered Tax Agreements.

The MLI’s signatories can decide which clauses they want to accept and how they want them to be adopted. Only when both treaty parties agree on the provisions of the MLI may a Covered Tax Agreement be changed. The ratification of the MLI by the treaty partner precedes the implementation of the agreed-upon adjustments to a Covered Tax Agreement. You can find Singapore’s stances on the MLI provisions at this link (PDF, 355KB).

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