The Inland Revenue Authority of Singapore has announced the signing on 9 December 2019 of an amending protocol to the 2004 income and capital tax treaty with Germany. Changes made by the protocol include:
- Article 5 (Permanent Establishment) is amended to extend the time period test after which a construction PE is deemed constituted from 6 months to 12 months;
- Article 10 (Dividends) is amended to reduce the general withholding tax rate from 15% to 10% (the 5% rate for 10% holding is maintai…