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Singapore - Untd A Emirates Tax Treaty (as amended by 2014 protocol) — Orbitax Tax Hub

Note: This Treaty may be impacted by the Multilateral Convention to Implement Tax Treaty Related Measures to Prevent BEPS (MLI). MLI impact on Tax Treaties is available with the Orbitax International Tax Research & Compliance Expert.

ARTICLE 4

Resident

(1) For the purposes of this Agreement, the term "resident of a Contracting State" means any person who is a resident of a Contracting State in accordance with the taxation laws of that State.

(2) For the purpose of paragraph 1, the term "a resident of a Contracting State" shall include:

  • (a) in the case of United Arab Emirates:
    • (i) the Federal Government and local Governments;
    • (ii) a political subdivision of U.A.E.;
    • *(iii) the U.A.E. Central Bank, Abu Dhabi Investment Authority, Investment Corporation of Dubai, Mubadala Development Company and Emirates Investment Authority;
    • *(iv) any other statutory body, institution or entity which is a resident of the United Arab Emirates.
  • (b) in the case of Singapore:
    • (i) the Government of Singapore;
    • *(ii) the Monetary Authority of Singapore and GIC Private Limited;
    • *(iii) any other statutory body, institution or entity which is a resident of Singapore.

(3) Where by reason of the provisions of paragraph 1 an individual is a resident of both Contracting States, then his case shall be determined in accordance with the following rules:

  • (a) he shall be deemed to be a resident of the Contracting State in which he has a permanent home available to him. If he has a permanent home available to him in both Contracting States, he shall be deemed to be a resident of the Contracting State with which his personal and economic relations are closer (centre of vital interests);
  • (b) if the Contracting State in which he has his centre of vital interests cannot be determined, or if he has not a permanent home available to him in either Contracting State, he shall be deemed to be a resident of the Contracting State in which he has an habitual abode;
  • (c) if he has an habitual abode in both Contracting States or in neither of them, the competent authorities of the Contracting States shall settle the question by mutual agreement.

(4) Where by reason of the provisions of paragraph 1 a person other than an individual is a resident of both Contracting States, then it shall be deemed to be a resident of the State in which its place of effective management is situated. If its place of effective management cannot be determined, the competent authorities of the Contracting States shall settle the question by mutual agreement.