The new income tax agreement between Singapore and South Africa came into force on 16 December 2016. The treaty, signed on 23 November 2015 by South Africa and Singapore on 30 November, replaces the 1996 tax treaty between the two countries. Given the strong bilateral relationship between the two regions, Singapore`s businesses and investors are likely to find a welcoming environment in South Africa. Read more Both countries apply the credit method to eliminate double taxation. For dividends paid to a Singapore company, the credit also takes into account taxes on the profits on which the dividends are paid, provided that the Singapore company directly or indirectly owns at least 10% of the share capital of the South African company. The final protocol of the treaty stipulates that South Africa must inform Singapore and begin negotiations to ensure treatment comparable to that provided for the third country when South Africa concludes an agreement with a third country providing for a lower withholding tax rate on dividends. The provisions of the DBA apply to persons residing in one or both contracting states. For more information on the agreement between Singapore and South Africa on the prevention of double taxation and the prevention of income tax evasion, see the IRAS. The treaty provides that when a company is considered to be established in the two contracting states, the competent authorities agree to determine the company`s place of residence for the purposes of the treaty. In the absence of an agreement, the company is deemed not to fall within the scope of the treaty, with the exception of the provisions of Article 24 (Exchange of Information).
The agreement between the Government of the Russian Federation and the Government of the Republic of Albania to avoid double taxation on income taxes and DBAs is used to reduce the double taxation of income collected in a jurisdiction by a resident of another country related to income. The DBA between Singapore and South Africa, in force since 16 December 2016, obtains a double taxation exemption in the situation in which income is taxed for both countries. The 1996 tax treaty between the two countries no longer has any effect on the effective dates of the new treaty. Effective date: January 1, 2004 (Russia); July 1, 2004 (Australia) . . . . The benefits of the disposal of other property by a residence in a contracting state can only be taxed by that state. . . . In force: 1 January and 6 April 1996 (Ireland); January 1, 1996 (Russia) .
. The contract provides that a stable establishment is considered constituted when a company provides services through workers or other engaged personnel, when the activities of a related project continue within a contracting state for a period or periods exceeding 183 days over a 12-month period. Effective date: September 1, 2000 (South Africa); January 1, 2001 (Russia) . . . . The contract also provides that a stable establishment is considered constituted when a company engages in activities that consist or are related, for more than six months, to the exploration or exploitation of natural resources in a State party.