Revised India-Singapore Tax Treaty: Decoding The Third Protocol

Pursuant to the signing of the third protocol (Protocol) amending the India-Singapore Tax Treaty (Treaty) on 30 December 2016, the text of the Protocol has now been officially released by the Government of Singapore. We previously reported key changes of the Protocol basis the press release issued by the Ministry of Finance, Government of India in our Ergo Newsflash dated 2 January 2017. In furtherance, detailed amendments based on the text of the Protocol are set out below:

Applicability of "Mutual Agreement Procedure" to Transfer Pricing

The article on "Associated Enterprises" under the Treaty has been amended to provide that a corresponding adjustment to the income/profits of an enterprise of one contracting state would be made when an addition is made in the income of its associated enterprise in the other contracting state. In determining such adjustment, due regard shall be had to the other provisions of the Treaty, and the competent authorities of