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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 22

Elimination of Double Taxation

(1) In Slovakia, double taxation shall be eliminated as follows:

  • Slovakia, when imposing taxes on its residents, may include in the tax base upon which such taxes are imposed the items of income which according to the provisions of this Agreement may also be taxed in Singapore, but shall allow as a deduction from the amount of tax computed on such a base an amount equal to the tax paid in Singapore. Such deduction shall not, however, exceed that part of the Slovak tax, as computed before the deduction is given, which is appropriate to the income which, in accordance with the provisions of this Agreement, may be taxed in Singapore.

(2) In Singapore, double taxation shall be eliminated as follows:

  • Where a resident of Singapore derives income from Slovakia which, in accordance with the provisions of this Agreement, may be taxed in Slovakia, Singapore shall, subject to its laws regarding the allowance as a credit against Singapore tax of tax payable in any country other than Singapore, allow the Slovak tax paid, whether directly or by deduction, as a credit against the Singapore tax payable on the income of that resident. Where such income is a dividend paid by a company which is a resident of Slovakia to a resident of Singapore which is a company owning directly or indirectly not less than 10 per cent of the share capital of the first-mentioned company, the credit shall take into account the Slovak tax paid by that company on the portion of its profits out of which the dividend is paid.