On 23 October 2021, the Inland Revenue Authority of Singapore (IRAS) issued an updated edition of its e-tax guide on “avoidance of double taxation agreements” to add guidance on arbitration provisions in Singapore’s double tax treaties. This e-Tax Guide provides taxpayers with guidance on:
-The interpretation and application of Singapore’s DTAs; and
-The mutual agreement procedure (“MAP”) under Singapore’s DTAs
-The guidance also notes that arbitration clauses in Singapore’s tax treaties address situations where the competent authorities of the countries involved are unable to reach a resolution on an issue through mutual agreement procedure.
Taxpayers can request in writing that a MAP case be submitted to arbitration if certain conditions are met. The taxpayer must submit the application in writing to the competent authority of the contracting state in which he is domiciled. The request must contain sufficient information to identify the MAP case. It can be submitted electronically using the email addresses provided on the IRAS website.
