タックス・ヘイブン：ニュージーランドとシンガポールの二重課税防止協定が施行

New Zealand, Singapore Revised DTA In Force

by Mary Swire, Tax-News.com, Hong Kong
Friday, August 13, 2010

New Zealand's Revenue Ministry and Singapore's Ministry of Finance have announced that the revised double taxation agreement (DTA) between the two countries came into force on August 12.

The new DTA replaces the 1973 agreement between the two countries. Peter Dunne, New Zealand's Revenue Minister, explained that, "as well as generally modernising the treaty, the new agreement will bring withholding tax rates on dividends, interest and royalties more into line with New Zealand's new standard treaty rates, meaning reductions in tax rates in some instances."

Under the new agreement, withholding tax on dividends, set at 15% under the 1973 treaty, is reduced to 5% where an investor holds a direct investment in a company. The withholding tax on interest will be reduced from 15% to 10%, and the withholding tax on royalties reduces from 15% to 5%.

The new withholding rates will apply in New Zealand from October 1 this year, and in Singapore from January 1, 2011. The later effective date for Singapore reflects that country's system of imposing tax on income earned in the previous year.

Singapore's Ministry of Finance expressed the hope that the revised DTA incorporates changes that will further encourage and facilitate cross-border trade and investment between Singapore and New Zealand. It pointed out that the DTA also changes the period test for determining permanent establishments, and thus the liability for taxes.

Dunne said that New Zealand now has 35 DTAs, covering most of its important trade and investment partners.