Switzerland - IRAS

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Upon signature by both competent authorities, this Mutual Agreement is effective as from the date of the entry into force of the Agreement. Done at Bern on 29 May 2012 For the Swiss Competent Authority: Done at Singapore on 25 May 2012 For the Singapore Competent Authority: Jürg Giraudi State Secretariat for International Financial Matters SIF Chai Sui Fun Assistant Commissioner Tax Policy and International Tax Division Inland Revenue Authority of Singapore 24
ANNEX B CONVENTION BETWEEN THE GOVERNMENT OF THE REPUBLIC OF SINGAPORE AND THE SWISS CONFEDERATION FOR THE AVOIDANCE OF DOUBLE TAXATION WITH RESPECT TO TAXES ON INCOME AND ON CAPITAL The Government of the Republic of Singapore and the Swiss Federal Council, Desiring to conclude a Convention for the avoidance of double taxation with respect to taxes on income and on capital, Have agreed as follows: Article 1 This Convention shall apply to persons who are residents of one or both of the Contracting States. Article 2 1. This Convention shall apply to taxes on income and on capital imposed on behalf of each Contracting State or of its political subdivisions or local authorities, irrespective of the manner in which they are levied. 2. There shall be regarded as taxes on income and on capital all ordinary and extraordinary taxes imposed on total income, on total capital, or on elements of income or of capital, including taxes on gains from the alienation of movable or immovable property, as well as taxes on capital appreciation. 3. The existing taxes to which the Convention shall apply are, in particular: (a) in the Republic of Singapore: the income tax (hereinafter referred to as "Singapore tax"); (b) in <strong>Switzerland</strong>: the federal, cantonal and communal taxes 25
Page 1 and 2: AGREEMENT BETWEEN THE REPUBLIC OF S
Page 3 and 4: (c) (d) (e) (f) (g) the term "perso
Page 5 and 6: (c) (d) (e) (f) the maintenance of
Page 7 and 8: (b) (c) profits from the use, maint
Page 9 and 10: (a) (b) (c) interest derived and be
Page 11 and 12: 5. Gains from the alienation of any
Page 13 and 14: 3. The provisions of Articles 15, 1
Page 15 and 16: Swiss tax with respect to such divi
Page 17 and 18: Article 27 - Members of Diplomatic
Page 19 and 20: MOSES LEE Commissioner of Inland Re
Page 21 and 22: 6. With reference to Article 26 (a)
Page 23: ANNEX A Mutual Agreement regarding
Page 27 and 28: (ii) in the case of Switzerland: th
Page 29 and 30: Article 6 1. Income from immovable
Page 31 and 32: 2. However, such dividends may be t
Page 33 and 34: 5. Royalties shall be deemed to ari
Page 35 and 36: 3. The term "annuities" means a sta
Page 37 and 38: amount of the interest or royalties
Page 39 and 40: Article 27 This Convention shall re

Switzerland - IRAS

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