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 2011 income tax treaty with Spain. 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 new mandatory arbitration provisions, with respect to any tax paid, deemed paid or liable to be paid, before, on or after 1 July 2022;
• 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 2023; 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 January 2023.

Click the following link for the text of the 2011 Singapore-Spain Tax Treaty with MLI Impact.