On January 12, 2024 (published on January 30, 2024), the Netherlands entered into an agreement with Singapore on the application of the Mutual Agreement Procedure (MAP) under the Multilateral Instrument (MLI).
The agreementimplements the MAP of Article 26 of the MLI-covered tax treaty between the Netherlands and Singapore and Articles 16 and 19 (10) MLI. With respect to the application of the MAP, Singapore does make a reservation in the agreement with respect to national anti-abuse rules contained in domestic laws, regulations, case law and doctrine. The competent authorities may modify or supplement this Agreement by an exchange of letters between them.
The agreement is retroactive to January 1, 2020, being the date on which the MLI-covered tax treaty between the Netherlands and Singapore entered into force.
The content of this article is intended to provide a general guide to the subject matter. Specialist advice should be sought about your specific circumstances.
