The Inland Revenue Authority of Singapore (IRAS) issued, on 23 October, a revised edition of its e-tax guide on ‘avoidance of double taxation agreements’ to add guidance on arbitration provisions in Singapore’s double tax treaties.
The guidance noted that arbitration clauses in Singapore’s tax treaties address situations where the competent authorities of the countries involved are unable to reach resolution on an issue through mutual agreement procedure (MAP). Under Singapore’s tax treaties, the arbitration panel’s decision is usually binding on the competent authorities, unless the taxpayer pursues alternative domestic or foreign remedies.
Taxpayers can generally request arbitration if the competent authorities have been unable to reach resolution in the timeframe specified in the relevant tax treaty. Taxpayers seeking arbitration must submit such requests in writing.
For further details on the process, the guide states that taxpayers should refer to the relevant competent authority agreement on arbitration for the applicable treaty. The e-tax guide further includes information on Singapore’s tax treaty policy, common provisions, MAP and other tax treaty issues.