Regulation 1
Citation and commencement
This Order is the Income Tax (Singapore — Canada) (Avoidance of Double Taxation Convention) (Modifications to Implement Multilateral Instrument) Order 2019 and comes into operation on 1 December 2019.
/akn/sg/act/sub_leg/1947/ITA-S785-2019
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Quick answer
Income Tax (Singapore — Canada) (Avoidance of Double Taxation Convention) (Modifications to Implement Multilateral Instrument) Order 2019 is Singapore Subsidiary Legislation, cited as Subsidiary Legislation ITA-S785-2019 1947, currently marked in force and first recorded in 1947.
Citation and commencement
This Order is the Income Tax (Singapore — Canada) (Avoidance of Double Taxation Convention) (Modifications to Implement Multilateral Instrument) Order 2019 and comes into operation on 1 December 2019.
Purpose
This Order amends the arrangements made between the Government of the Republic of Singapore and the Government of Canada as specified in the Schedule to the Income Tax (Singapore — Canada) (Avoidance of Double Taxation Convention) Order 1977 (O 9) (called in this Order the Convention), as modified by the Protocol specified in the Schedule to the Income Tax (Singapore — Canada) (Avoidance of Double Taxation Convention) Order 2012 (G.N. No. S 368/2012).
The purpose of this Order is to amend the Convention to give effect to Singapore’s obligations under the Multilateral Convention to Implement Tax Treaty Related Measures to Prevent Base Erosion and Profit Shifting done at Paris on 24 November 2016 (as amended from time to time).
Amendment of Convention
The provisions of the Convention are amended in the manner set out in the Schedule.
Entry into effect
Paragraph 2 of the Schedule has effect for a case presented on or after 1 December 2019 without regard to the basis period to which the case relates.
Sub‑paragraph (1) does not apply to a case that was not eligible to be presented immediately before 1 December 2019.
Paragraph 3 of the Schedule has effect with respect to any tax paid, deemed paid or liable to be paid, before, on or after 1 December 2019.
All other paragraphs of the Schedule have effect —
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
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 June 2020.