Philippines-Singapore DTAA: Double Tax Avoidance Agreement

This guide provides an overview of the Philippines-Singapore Double Tax Treaty, one of the numerous economic bilateral agreements between the two countries. The article describes the scope of the treaty, types of taxes covered, specific rules on taxation of different types of income, rules that govern the elimination of double taxation, and other pertinent issues covered by the agreement.

If you are planning to incorporate a Singapore company and do business with the Philippines, this guide will help you understand the tax treatment of various sources of Philippines-related income for your company.

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2024 Guide on Philippines-Singapore Double Tax Treaty (DTA)

Philippines-Singapore Relations

Singapore and the Philippines have strong bilateral economic ties since diplomatic relations were formally established between the countries in 1969. A significant milestone to create deeper economic cooperation was established in 1998 when the two countries signed the Memorandum of Understanding on the Philippines-Singapore Action Plan. As a result of the implementation of the Action Plan, Singapore has become the Philippines’ fifth largest export market worldwide and the first within ASEAN region. Singapore is the Philippines' top international investor, with investment commitments totaling US$3.48 billion of total foreign pledges in 2019.
This deep economic integration between the two countries is a result of the bilateral agreements that were designed to enhance and simply business transactions between the two markets. Below are listed some of the important bilateral agreements that currently exist between Singapore and the Philippines.

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singapore-philippines dta overview

What is the Philippines-Singapore Double Tax Treaty?

The Singapore-Philippines Avoidance of Double Taxation Agreement (DTAA) stipulates provisions for avoiding double taxation on the same income. Any income taxable in both countries will be taxed only in one country, or in both but at reduced rates. This tax reduction has been developed to encourage cross-border trade and other business activities between the two countries.

Singapore and the Philippines concluded a DTAA  in 1977. The agreement ensures that any income normally taxable in both countries will be taxed in only one of them. The provisions of this DTAA are reviewed in more detail below.

Scope of the Philippines-Singapore Double Tax Treaty (DTA)

How is Tax Residency Defined Under the Singapore-Philippines 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 Philippines–Singapore DTAA is that residency determines tax jurisdiction. Companies and individuals are taxable in the country where they reside. The question of whether a person is a resident of a state is normally settled by the national laws of each country. The DTAA, however, provides rules to determine residency in a case where a person may be resident in both of the signatory states.

What Taxes Will I Owe Under the Philippines-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 Singapore-Philippines DTAA specifically states where different types of income of a resident of either Singapore or the Philippines 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

Profits from the operation of ships or aircraft used in international traffic are taxable only in the state where the enterprise that owns the vehicle is a resident (i.e. where a company is managed and controlled).

May also be taxed at reduced rates in the state where ships or aircraft are operated.


May be taxed in the state where the recipient resides and in the state where dividends arise.


May be taxed in the state where the recipient resides and in the state where interest arises.


May be taxed in the state where the recipient resides and in the state where royalties arise.

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.


Taxed in the state where they arise.

Government payments

Taxed in the state that pays the remuneration.

Payments to students and trainees

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

Payments to teachers and researchers

Taxed in the state where they reside. May be taxed in the state of education/work 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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As Singapore and the Philippines become integrated into the global trade system, a rising proportion of their firms are establishing businesses abroad and deriving income from overseas jurisdictions. One of the main regulatory instruments that helps Singapore and Philippines companies reduce their tax burden is the DTA signed between the two jurisdictions.

Comprehensive knowledge and familiarity with the rules for double taxation relief are crucial when establishing corporate structures that span the two countries or while filing annual income tax returns. When in doubt, consulting qualified tax experts will reduce your tax risk, optimize your taxes and ease your life. Please contact us to ensure you don’t lose out on opportunities for claiming double-tax relief in Singapore.

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