The Inland Revenue Authority of Singapore (IRAS) has published the impact of the Multilateral Convention to Implement Tax Treaty Related Measures to Prevent Base Erosion and Profit Shifting (MLI) for the 2006 income tax treaty with Belgium. Rather than including the MLI impacts directly within the text of the treaty as some countries have done (so-called synthesized texts), the impacts are provided in a new Annex A to the treaty. The impacts of the MLI on the treaty have effect in Singapore:

• For the extension of MAP for the elimination of double taxation in cases not provided for in the treaty, for a case presented on or after 1 October 2019 without regard to the basis period to which the case relates, except for a case that was not eligible to be presented immediately before 1 October 2019;
• For the new mandatory arbitration provisions, with respect to any tax paid, deemed paid or liable to be paid, before, on or after 1 October 2019;
• For all other MLI impacts:
  • with respect to taxes withheld at source, in respect of amounts paid, deemed paid or liable to be paid (whichever is the earliest), on or after 1 January 2020; and
  • with respect to taxes other than those withheld at source, where the income is derived or received in a basis period beginning on or after 1 April 2020.

Click the following link for the text of the 2006 Belgium-Singapore Tax Treaty with MLI Impact.