Canada - IRAS

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PROTOCOL (1976) At the signing of the Convention between the Government of Canada and the Government of the Republic of Singapore for the Avoidance of Double Taxation with respect to Taxes on Income, the undersigned have agreed on the following provisions which shall be an integral part of the Convention. 1. With reference to paragraph 1 of Article 8 and paragraph 3 of Article 14, the term "international traffic" shall not include voyages between places in a Contracting State and one or more movable bases situated in waters other than the territorial waters of either Contracting State. 2. With reference to the said Convention, nothing therein stated shall be construed as preventing Canada from imposing its tax on amounts included in the income of a resident in Canada according to Section 91 of the Canadian Income Tax Act. IN WITNESS WHEREOF the undersigned, duly authorised thereto, have signed this Protocol. Done in Singapore, this 6th day of March of the year one thousand nine hundred and seventy-six in duplicate in the English and French languages, each version being equally authentic. For the Government of the Republic of Singapore: HON SUI SEN For the Government of Canada: DONALD JAMIESON 16
ANNEX A PROTOCOL AMENDING THE CONVENTION BETWEEN THE GOVERNMENT OF THE REPUBLIC OF SINGAPORE AND THE GOVERNMENT OF CANADA FOR THE AVOIDANCE OF DOUBLE TAXATION AND THE PREVENTION OF FISCAL EVASION WITH RESPECT TO TAXES ON INCOME, DONE IN SINGAPORE ON 6 MARCH 1976 The Government of the Republic of Singapore and the Government of Canada, Desiring to amend the Convention between the Government of the Republic of Singapore and the Government of Canada for the Avoidance of Double Taxation and the Prevention of Fiscal Evasion with respect to Taxes on Income, done in Singapore on 6 March 1976 (“the Convention”), Have agreed as follows: ARTICLE I The text of Article 25 (Exchange of Information) of the Convention is deleted and replaced by the following: “1. The competent authorities of the Contracting States shall exchange such information as is foreseeably relevant for carrying out the provisions of this Convention or to the administration or enforcement of the domestic laws concerning taxes of every kind and description imposed on behalf of the Contracting States, insofar as the taxation thereunder is not contrary to the Convention. The exchange of information is not restricted by Articles 1 and 2. 2. Any information received under paragraph 1 by a Contracting State shall be treated as secret in the same manner as information obtained under the domestic laws of that State and shall be disclosed only to persons or authorities (including courts and administrative bodies) concerned with the assessment or collection of, the enforcement in respect of, the determination of appeals in relation to taxes, or the oversight of the above. Such persons or authorities shall use the information only for such purposes. They may disclose the information in public court proceedings or in judicial decisions. 3. In no case shall the provisions of paragraphs 1 and 2 be construed so as to impose on a Contracting State the obligation: (a) to carry out administrative measures at variance with the laws and administrative practice of that or of the other Contracting State; 17
Page 1 and 2: CONVENTION BETWEEN THE GOVERNMENT O
Page 3 and 4: (ii) any legal person, partnership
Page 5 and 6: 7. The fact that a company which is
Page 7 and 8: addition to the tax chargeable on t
Page 9 and 10: the right or property in respect of
Page 11 and 12: ARTICLE 17 - PENSIONS AND ANNUITIES
Page 13 and 14: ARTICLE 23 - NON-DISCRIMINATION 1.
Page 15: non-residents on or after the first

Canada - IRAS

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