Article 22 - Income of Government - Singapore

ARTICLE 22 INCOME OF GOVERNMENT 1. The Government of a Contracting State shall be exempt from tax in the other Contracting State in respect of income derived by that Government from sources within the other State. 2. The types of income to which paragraph 1 applies are: (a) dividends under Article 10; (b) interest under Article 11; and (c) any other income or gains derived from transactions not pursuant to the conduct of commercial activities. 3. For the purposes of paragraph 1, the term Government : (a) in the case of Singapore means the Government of Singapore and shall include: (i) the Monetary Authority of Singapore and the Board of Commissioners of Currency; (ii) the Government of Singapore Investment Corporation Pvt. Ltd. to the extent it is not engaged in the conduct of commercial activities; (iii) a statutory body not engaged in the conduct of commercial activities; (iv) any other institution or body as may be agreed from time to time between the competent authorities of the Contracting States; (b) in the case of India means the Government of India and shall include: (i) the Governments of the States and the Union Territories of India; (ii) the Reserve Bank of India or any of its subsidiaries which is not engaged in the conduct of commercial activities; (iii) a statutory body not engaged in the conduct of commercial activities; (iv) any other institution or body as may be agreed from time to time between the competent authorities of the Contracting States.