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TMI BlogProtocol amending the Agreement between the Government of the Republic of India and the Government of the Republic of Singapore for the Avoidance of Double Taxation and the Prevention of Fiscal Evasion with respect to Taxes on IncomeX X X X Extracts X X X X X X X X Extracts X X X X ..... on 1st August, 2005 under Article 7 of the Protocol amending the Agreement for giving effect to the provisions of the said Protocol; Now, therefore, in exercise of the powers conferred by section 90 of the Income-tax Act, 1961 (43 of 1961), the Central Government hereby directs that all the provisions of the said Protocol amending the Agreement between the Government of the Republic of India and the Government of the Republic of Singapore for The Avoidance of Double Taxation and the Prevention of Fiscal Evasion with respect to Taxes on Income shall be given effect to in the Union of India with effect from the 1st day of August, 2005. [Notification No. 185/2005/F. No. 500/139/2002-FTD] POONAM DUTT, Jt. Secy. PROTOCOL AMENDING THE AGREEM ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... his Protocol if its affairs were arranged with the primary purpose to take advantage of the benefits in Article 1 of this Protocol. 2. A shell/conduit company that claims it is a resident of a Contracting State shall not be entitled to the benefits of Article 1 of this Protocol. A shell/conduit company is any legal entity falling within the definition of resident with negligible or nil business operations or with no real and continuous business activities carried out in that Contracting State. 3. A resident of a Contracting State is deemed to be a shell/conduit company if its total 1[annual expenditure] on operations in that Contracting State is less than S$200,000 or Indian Rs. 50,00,000 in the respective Contracting State as the case ma ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... arise and according to the laws of that Contracting State, but if the recipient is the beneficial owner of the royalties or fees for technical services, the tax so charged shall not exceed 10%. ARTICLE 5 It is agreed that there shall be an inter-governmental group consisting of representatives of the revenue authorities of the two Contracting States which shall review the working of the provisions of this Protocol at least once a year or earlier at the request of either Contracting State and may make recommendations for improvements including improvements to the provisions of this Protocol. ARTICLE 6 Articles 1, 2, 3 and 5 of this Protocol shall remain in force so long as any Convention or Agreement for the Avoidance of Double Taxation ..... X X X X Extracts X X X X X X X X Extracts X X X X
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