Tax Treaty-Related Measures implemented to Prevent Base Erosion and Profit Shifting through the Multilateral Convention

  • September 08, 2022

Singapore’s participation in the negotiation of the MLI (Multilateral Instrument) is in line with its commitment to implement the minimum standard for preventing treaty abuse. The MLI is intended to enable jurisdictions to swiftly amend their tax treaties to implement the tax treaty-related Base Erosion and Profit Shifting.

Date

What’s new
1 September 2022 The amendments to Singapore’s DTA with China made by the MLI took effect today. More information on these amendments can be found on IRAS’s DTA listing page.
1 July 2022 The amendments to Singapore’s DTAs with Spain and Thailand made by the MLI took effect today. More information on these amendments can be found on IRAS’s DTA listing page.
1 June 2022 The amendments to the Singapore-Bahrain DTA made by the MLI entered into force today. More information on these amendments can be found on IRAS’s DTA listing page.
1 April 2022 The amendments to Singapore’s DTAs with Spain and Thailand made by the MLI took effect today. More information on these amendments can be found  IRAS’s DTA listing page.
1 July 2021 The amendments to Singapore’s DTA with Hungary made by the MLI took effect on this day. More information on these amendments can be found on IRAS’s DTA listing page.
1 June 2021 The amendments to Singapore’s DTA with Malaysia made by the MLI took effect on this day. More information on these amendments can be found on IRAS’s DTA listing page.
1 April 2021 The amendments to Singapore’s DTAs with Barbados and Pakistan made by the MLI took effect on this day. More information on these amendments can be found on IRAS’s DTA listing page.
1 March 2021 The amendments to Singapore’s DTA with Panama made by the MLI took effect on this day. More information on these amendments can be found on IRAS’s DTA listing page.
1 January 2021 The amendments to Singapore’s DTAs with Albania and Egypt made by the MLI took effect on this day. More information on these amendments can be found on IRAS’s DTA listing page.
26 December 2020 The amendments to Singapore’s DTA with Indonesia made by the MLI took effect on this day. More information on these amendments can be found on IRAS’s DTA listing page.
1 November 2020 The amendments to Singapore’s DTA with Oman made by the MLI took effect on this day. More information on these amendments can be found on IRAS’s DTA listing page.
1 October 2020 The amendments to Singapore’s DTA with Kazakhstan made by the MLI took effect on this day. More information on these amendments can be found on IRAS’s DTA listing page.
1 September 2020 The amendments to Singapore’s DTA with the Czech Republic made by the MLI took effect on this day. More information on these amendments can be found on IRAS’s DTA listing page.
1 July 2020

The amendments to Singapore’s DTA with San Marino made by the MLI took effect on this day. More information on these amendments can be found on IRAS’s DTA listing page.

1 June 2020 The amendments to Singapore’s DTAs with Portugal and Uruguay made by the MLI took effect on this day. More information on these amendments can be found on IRAS’s DTA listing page.
30 May 2020 The amendments to Singapore’s DTA with Russia made by the MLI took effect on this day. More information on these amendments can be found on IRAS’s DTA listing page.
1 May 2020 The amendments to Singapore’s DTAs with Cyprus and Saudi Arabia made by the MLI took effect on this day. More information on these amendments can be found on IRAS’s DTA listing page.
1 April 2020 The amendments to Singapore’s DTAs with Liechtenstein and Qatar made by the MLI took effect on this day. More information on these amendments can be found on  IRAS’s DTA listing page.
1 February 2020 The amendments to Singapore’s DTAs with Latvia and Mauritius made by the MLI took effect on this day. More information on these amendments can be found on IRAS’s DTA listing page.
1 January 2020 The amendments to Singapore’s DTA with Denmark made by the MLI took effect on this day. More information on these amendments can be found on IRAS’s DTA listing page.
1 December 2019 The amendments to Singapore’s DTAs with Canada and Ukraine made by the MLI took effect on this day. More information on these amendments can be found on  IRAS’s DTA listing page.
1 October 2019 The amendments to Singapore’s DTAs with Belgium and India made by the MLI took effect on this day. Details of these amendments can be found on IRAS’s DTA listing page.
1 September 2019 The amendments to Singapore’s DTA with United Arab Emirates made by the MLI took effect on this day. More information on these amendments can be found on IRAS’s DTA listing page.
1 August 2019 The amendments to Singapore’s DTA with Luxembourg made by the MLI took effect on this day. More information on these amendments can be found on  IRAS’s DTA listing page.
1 July 2019 The amendments to Singapore’s DTAs with Georgia and the Netherlands made by the MLI took effect on this day. More information on these amendments can be found on  IRAS’s DTA listing page.
1 June 2019 The amendments made by the MLI to Singapore’s DTAs with Finland and Guernsey took effect on this day. More information on these amendments can be found on IRAS’s DTA listing page.
1 May 2019 The amendments to Singapore’s DTA with Ireland took effect made by the MLI on this day. More information on these amendments can be found on  IRAS’s DTA listing page.
1 April 2019

The MLI has entered into force for Singapore.

The amendments made by the MLI to Singapore’s DTAs with Australia, Austria, France, Isle of Man, Israel, Japan, Jersey, Lithuania, Malta, New Zealand, Poland, Slovak Republic, Slovenia, and the United Kingdom have taken effect on this day. More information on these amendments can be found on IRAS’s DTA listing page.

21 December 2018

Singapore deposited its instrument of ratification for the MLI. The MLI will enter into force for Singapore on 1 April 2019.

Read the press release.

1 July 2018 The MLI came into effect after five jurisdictions deposited their instruments of ratification.
7 June 2017

Singapore signed the Multilateral Convention on Mutual Administrative Assistance in Tax Matters at the first signing ceremony held in Paris.

Read the press release.

24 November 2016 (Paris time)

More than 100 jurisdictions (including Singapore) concluded the negotiation of the MLI.

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 MLI will come into effect for Singapore on 21 December 2018. At that time, a list of DTAs that Singapore intends to amend using the MLI will be available at this link (PDF, 135KB). These DTAs will only be amended if Singapore’s treaty partners also choose to amend the DTAs using the MLI.

The MLI provides that signatories may choose the provisions to adopt and how such provisions should be adopted. A Covered Tax Agreement will only be amended if both treaty partners share the same position on the provisions of the MLI. The agreed changes to a Covered Tax Agreement will be effective once both parties have notified each other of their ratification. Singapore’s positions on the MLI provisions can be found at this link (PDF, 355KB).

View the list of DTAs that Singapore (PDF, 1360KB) and other jurisdictions (PDF, 155KB) would like to amend using the MLI as well as the positions that Singapore and the other jurisdictions have adopted for the MLI.

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