Netherlands-Singapore DTAA: Double Tax Avoidance Agreement

While conducting business in several countries it is crucial to understand the tax consequences you may face doing cross-border business activities. In this guide, we will explain the benefits the Netherlands-Singapore confers on Singapore-based companies; the types of taxes the agreement covers; the principles of tax relief; and other provisions of the DTAA that may be important to your business.
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Netherlands-Singapore DTAA: Double Tax Avoidance Agreement

Countries, like Singapore and the Netherlands, enter into bilateral tax agreements in order to prevent the double taxation of income, capital, and other taxable units. These agreements enable companies and individuals who operate in both countries to rationalize their tax payments such that they only have to pay taxes in one of the countries.

The Avoidance of Double Taxation Agreement (DTAA) between Singapore and the Netherlands came into force on September 3, 1971. The agreement has been amended twice, by protocols that became effective on January 1, 1994, and May 1, 2010. Further changes were made on March 29, 2019, after the two countries ratified the Multilateral Instrument.

holland-singapore dta

What Is the Netherlands-Singapore Double Tax Treaty?

With the globalization of commerce, it has become common for a company or individual resident in one state to receive taxable income in another country. This often meant paying taxes in both countries - the country of one’s residence and the country from where the income is received. Since this type of “double” taxation is inequitable, Singapore and the Netherlands have concluded a bilateral double-taxation agreement to prevent it by adopting special mechanisms for resolving this situation.

An agreement may specify that the tax must be paid in the country of residence and will be exempt in the jurisdiction where the income arises. In the remaining cases, the resident must pay tax to the country where the income is generated and the taxpayer receives a compensating foreign tax credit in the country of residence.

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Scope of the Netherlands-Singapore Tax Treaty

The scope of the Netherlands-Singapore DTAA covers the type of persons and the types of taxes to which the treaty applies as described below.

How is Tax Residency Defined Under the Singapore-Netherlands DTA?

The main goal of a DTAA is to determine in which state a person must pay taxes. The basic principle for this determination in the Netherlands–Singapore DTAA is based on residency. Companies and individuals are taxable in the country where they reside. The question of whether a person is a resident of a state is settled by national laws. However there are situations where, under national laws, you may be considered to be a resident of both states. To avoid double taxation, the DTAA establishes the rules to determine the tax residency.
The tax residency is determined using the above rules and the entity or individual is only taxed in the state of residency. However, the DTAA has additional rules for certain types of income which are explained further below.

What Taxes Will I Owe Under the Netherlands-Singapore Double Tax Avoidance Agreement?

The tax you owe will depend on the country where you have to pay the tax which further depends on the type of income involved. Taxes on various types of income are described in the following sections.

In Which Country Will the Income be Taxed?

The DTAA specifically states where different types of income of a resident of either Singapore or the Netherlands will be subject to tax. The following table states the type of income or payments made and the state where the income is taxed. This is important since the place of taxation will determine the rate of tax applicable to that type of income under the DTAA.

Type of income or payment

Where it is taxed

Income from immovable property

Taxed in the state where the property is situated.

Business profits

Taxed in the state where a company is managed and controlled — typically, the country of the company's Board of Directors meetings.

Permanent Establishment profits

Taxed in the state where it carries on business activities, but only in the amount attributable to that PE.

Profits from shipping and air transport

Taxed in the state where a company is managed and controlled. If some passengers are boarded or goods loaded in the other state, it may be taxed in that other state, but only upon profits derived there.


Taxed in the state where the recipient resides.


Taxed in the state where the recipient resides.


Taxed in the state where the recipient resides.

Capital gains

Taxed in the state of residency of the seller.


Taxed in the state where the owner resides.

Personal Services

Taxed in the worker’s state of residency.

Directors’ fees

Taxed in the state where the company (paying the directors’ fees) resides.

Income of artists and sports persons

Taxed in the state where activities are performed.

Pensions and Annuity

Taxed in the state where the recipient resides.

Government payments

Taxed in the state where the government functions are carried out. If a resident of the other state, not being a citizen or national of the first state, carries out governmental functions, the remuneration is taxed in the state where the recipient resides.

Payments to students, researchers, and scientists

Taxed in the state where they reside. May be taxed in the state of education if the payment does not fall under exemptions.

Protect Your Income From Excessive Taxation

To effectively grow your business and maximize profits, it’s essential to understand the tax benefits available to you and your business. If you’re considering incorporating your company in Singapore, can help you navigate the process by helping select the correct corporate structure that will minimize your taxes while fully complying with all government laws, regulations, and DTAAs.
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The Netherlands–Singapore DTAA establishes the rules by which taxes are levied on companies and individuals who reside in one country but receive income from the other. You can find the full text of the Netherlands-Singapore DTAA.

The main goal of this document is to reduce the overall tax burden. Pursuant to the signing of the agreement, any income taxable in both countries will be taxable only in one country. This tax reduction is designed to encourage cross-border trade and other business activities between the two countries. can help you with tax advice or tax planning issues for your business if you operate in Singapore and the Netherlands — and ensure that your company stays in compliance with Singapore’s tax regulations.

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