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The new income tax treaty and protocol between Singapore and Malaysia, signed on 5 October 2004, entered into force on 13 February 2006. In Singapore, the treaty will generally apply from 1 January 2007. In Malaysia, the treaty will apply in respect of petroleum income tax to income derived on or after 1 January 2008 and in respect other tax from 1 January 2007. From these dates, the new treaty generally replaces the Singapore and Malaysia income tax treaty of 26 December 1968.

16 March 2006

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Treaty Development

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Singapore-Malaysia

The maximum rates of withholding tax are: -   10% on dividends in general, and 5% if the beneficial owner is a company that holds directly at least 25% of the capital of the company paying the dividends. However, neither Malaysia nor Singapore currently imposes a dividend withholding tax; -   10% on interest, subject to exemptions for interest on Malaysian approved loans and interest derived by the government (as defined); -   8% on royalties; and -   5% of technical fees. Deviations from the OECD Model include: -   a permanent establishment includes a building site, or construction,...