- The Agreement between the Government of the Republic of Singapore and the Government of the Republic of Armenia for the Elimination of Double Taxation with respect to Taxes on Income and the Prevention of Tax Evasion and Avoidance (“DTA”), signed on 8 July 2019, entered into force on 23 December 2021.
- The DTA will benefit businesses in both Singapore and Armenia as well as boost bilateral trade and investment flows between the two countries. For more information on this DTA, please refer to our press release here issued on 8 July 2019. Key terms of the DTA can be found in the Annex. The full text of the DTA is available on the Inland Revenue Authority of Singapore’s website here.
MINISTRY OF FINANCE
23 December 2021
Annex: Summary of key terms in the Singapore-Armenia DTA
|Article in the DTA||Key terms in the DTA|
|Article 5, Permanent Establishment||· Threshold of nine months for construction-related activities, beyond which residents of a contracting state could trigger a taxable presence in the other contracting state|
· Threshold of 183 days in any twelve-month period for the furnishing of services by an enterprise of a contracting state within the other contracting state
|Article 10, Dividends||· 0% withholding tax rate (if shareholding ≥ 25% or investment in share capital ≥ US$300,000)|
· 5% withholding tax rate (all other cases)
|Article 11, Interest||· 5% withholding tax rate|
|Article 12, Royalties||· 5% withholding tax rate|