Germany-Singapore Double Taxation Agreement: Current Status
German entrepreneurs seeking business banking in Singapore benefit from an active Double Taxation Agreement between Germany and Singapore. The original agreement was signed in 1972 and has been significantly updated through a protocol signed on December 9, 2019, which entered into force on March 29, 2021.
The updated protocol introduces several important provisions that affect German business operations in Singapore, including modern anti-abuse measures and enhanced exchange of information provisions.
Key Protocol Updates (2019/2021)
- Principal Purpose Test (PPT): Anti-treaty abuse provisions ensure legitimate business purposes (Source: PWC Singapore Tax Bulletin)
- Extended PE Threshold: Permanent establishment threshold extended to 12 months for construction projects (Source: PWC)
- Arbitration Mechanism: Dispute resolution procedures for unresolved mutual agreement procedure cases (Source: IRAS)
- Enhanced Information Exchange: Updated provisions for tax information sharing between authorities (Source: IRAS)
These provisions demonstrate the commitment of both governments to facilitate legitimate business activities while preventing treaty abuse. German entrepreneurs should consult qualified tax advisors to understand how these provisions apply to their specific situations.