Singapore – Poland Double Tax Treaty

Singapore and Poland signed a treaty for the avoidance of double taxation on 23rd of April 1993; the agreement has been amended later (in November 2012) and it became effective from 1st of February 2015. Poland investors interested in opening a company in Singapore can benefit of the provisions of the treaty by receiving tax deductions and exemptions. If you are seeking to expand your business activity here, our Singaporean lawyers can provide you with an in-depth presentation on the double taxation treaty (DTA) signed by the two contracting states. 

 

 

The agreement applies to the taxation of income in both contracting states. The tax is applicable to the total income of a company set up in the contracting states or to elements of income, such as gains received from the alienation of movable or immovable property. 

 

The DTA covers the following taxes:

 

• the income tax, applicable on the Singaporean territory;

• the personal income tax and the corporate income tax, applicable under the Polish legislation. 

 

According to the DTA, a resident in a contracting state is a person or a legal entity who is considered a tax resident, under the stipulations of the local legislation. 

 

A permanent establishment (PE) refers to a business settlement in which a company carries its operations and it may refer to a branch, an office, a factory, a workshop or a mine, but it can also be represented by a building or a construction site. The Singapore - Poland DTA stipulates that such a place of business is considered a PE as long as the company’s activities last longer than a year. The DTA also refers to the furnishing of services, which can become a PE if the services offered by the employees of a Polish company in Singapore last longer than 365 days in a 15 months period. 

 

 

The Singapore – Poland DTA stipulates that the dividends which have to be paid by Polish company to a Singaporean company can be taxed in Singapore. The dividends can also be paid in Poland, but if the beneficial owner is a resident of Singapore, the dividends will be taxed at a rate of 5% or 10% of the gross amount of the dividends; our law firm in Singapore can provide you with further information on taxation rates of dividends under the DTA. 

 

If you need further information on the stipulation of the Singapore –Poland DTA, please contact our lawyers in Singapore for consultations on this matter.