The Inland Revenue Authority of Singapore has announced the entry into force of the amending protocol to the 2004 income and capital tax treaty with Germany on 29 March 2021. Changes made by the protocol include the following:
- 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 …