Canada - IRAS

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ARTICLE 21 - LIMITATION OF RELIEF Where this Convention provides (with or without other conditions) that income from sources in a Contracting State shall be exempt from tax, or taxed at a reduced rate in that Contracting State and under the laws in force in the other Contracting State the said income is subject to tax by reference to the amount there of which is remitted to or received in that other Contracting State and not by reference to the full amount thereof, then the exemption or reduction of tax to be allowed under this Convention in the first-mentioned Contracting State shall apply to so much of the income as is remitted to or received in that other Contracting State. ARTICLE 22 - ELIMINATION OF DOUBLE TAXATION 1. The laws in force in either of the Contracting States shall continue to govern the taxation of income in the respective Contracting States except where express provisions to the contrary is made in this Convention. Where income is subject to tax in both Contracting States, relief from double taxation shall be given in accordance with the following paragraphs of this Article. 2. In the case of Canada, double taxation shall be avoided as follows: (a) (b) Subject to the existing provisions of the law of Canada regarding the allowance as a credit against Canadian tax of tax payable in any country other than Canada and to any subsequent modifications of those provisions - which shall not affect the general principle hereof - and unless a greater deduction or relief is provided under the laws of Canada, tax payable in Singapore on profits, income or gains arising in Singapore shall be allowed as a credit against Canadian tax payable in respect of such profits, income or gains. Subject to the existing provisions of the law of Canada regarding the determination of the exempt surplus of a foreign affiliate and to any subsequent modifications of those provisions -- which shall not affect the general principle hereof -- for the purpose of computing Canadian tax a company resident in Canada shall be allowed to deduct in computing its taxable income any dividend received by it out of the exempt surplus of a foreign affiliate resident in Singapore. 3. In the case of Singapore, subject to the existing provisions of the law of Singapore regarding the allowance as a credit against Singapore tax of tax payable in any country other than Singapore and to any subsequent modifications of those provisions - which shall not affect the general principle hereof - tax payable in Canada on profits, income or gains arising in Canada shall be allowed as a credit against Singapore tax payable in respect of such profits, income or gains. 4. For the purposes of paragraph 2 of this Article, tax payable in Singapore shall be deemed to include Singapore tax which would have been paid if the Singapore tax had not been exempted in accordance with the provisions of Part VI of the Economic Expansion Incentives (Relief from Income Tax) Act (1970 Edition) of Singapore, so far as they were in force on, and have not been modified since, the date of the signature of this Convention, or have been modified only in minor respects so as not to affect their general character. 12
ARTICLE 23 - NON-DISCRIMINATION 1. The citizens of a Contracting State shall not be subjected in the other Contracting State to any taxation or any requirements connected therewith which are other or more burdensome than the taxation and connected requirements to which citizens of that other State in the same circumstances are or may be subjected. 2. The taxation on a permanent establishment which an enterprise of a Contracting State has in the other Contracting State shall not be less favourably levied in that other State than the taxation levied on enterprises of that other State carrying on the same activities. 3. Nothing in this Article shall be construed as obliging: (a) (b) a Contracting State to grant to residents of the other Contracting State any personal allowances, reliefs and reductions for tax purposes which it grants to its own residents; Singapore to grant to citizens of Canada not resident in Singapore those personal allowances, reliefs and reductions for tax purposes which are by law available on the date of signature of this Convention only to citizens of Singapore whether or not they are resident in Singapore. 4. In this Article, the term "taxation" means taxes which are the subject of this Convention. ARTICLE 24 - MUTUAL AGREEMENT PROCEDURE 1. Where a resident of a Contracting State considers that the actions of one or both of the Contracting States result or will result for him in taxation not in accordance with this Convention, he may, without prejudice to the remedies provided by the national laws of those States, address to the competent authority of the Contracting State of which he is a resident an application in writing stating the grounds for claiming the revision of such taxation. To be admissible, the said application must be submitted within two years from the first notification of the action which gives rise to taxation not in accordance with the Convention. 2. The competent authority referred to in paragraph 1 shall endeavour, if the objection appears to it to be justified and if it is not itself able to arrive at an appropriate solution, to resolve the case by mutual agreement with the competent authority of the other Contracting State, with a view to the avoidance of taxation not in accordance with the Convention. 3. The competent authorities of the Contracting States shall endeavour to resolve by mutual agreement any difficulties or doubts arising as to the interpretation or application of the Convention. 4. The competent authorities of the Contracting States may communicate with each other directly for the purpose of applying this Convention. ARTICLE 25 - EXCHANGE OF INFORMATION 1. The competent authorities of the Contracting States shall exchange such information as is necessary for the carrying out of this Convention and of the domestic laws of the 13
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Page 3 and 4: (ii) any legal person, partnership
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Page 15 and 16: non-residents on or after the first
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Canada - IRAS

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