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PwC Singapore l Tax Services
Singapore and India signed a new protocol to update tax treaty
Singapore and India have concluded a protocol on 30 December 2016 to amend certain
terms of the Singapore-India double tax agreement (DTA). Very broadly, the key changes
from the perspective of a Singapore resident investor are:
1. Grandfathering of capital gains tax exemption in India for disposal of shares in Indian
resident companies acquired before 1 April 2017.
2. Introduction of a two-year transition period for shares acquired on or after 1 April 2017,
where any gains on disposal of shares in an Indian resident company derived between 1
April 2017 and 31 March 2019 may be taxed in India but at no more than half of the
3. Inclusion of Article 9(2), which provides for the basis of making a corresponding
adjustment in one state when a transfer pricing adjustment is made by another state to
reflect adherence to the arm's length principle in related party transactions.
4. It is also provided that the DTA will not prevent each state from applying its domestic
law and measures to curb tax avoidance or evasion.
Further, it was announced that the two governments have agreed on steps towards a set of
new initiatives for joint promotion of bilateral investments with a view to concluding an
agreement in the second half of 2017.
Details are available at:
Income Tax (Amendment No. 3) Act 2016
The Income Tax (Amendment No. 3) Act 2016 was published on 29 December 2016.
There are no changes to the Bill.
Tax updates for the period
1 December 2016 to
13 January 2017
Common Reporting Standard (CRS)
The Income Tax (International Tax Compliance Agreements) (Commo