China-Singapore DTAA: Double Tax Avoidance Agreement

This article will highlight key areas of cooperation between Singapore and China and the main provisions of the China-Singapore DTAA that has played and continues to play a significant role in fostering economic and diplomatic relations between the two countries.
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China-Singapore DTAA: Double Tax Avoidance Agreement

Singapore-China Relations

The Singapore-China relationship is unique and multifaceted. A common cultural heritage and close geographic proximity has nurtured strong and enduring connections between the two countries, that span partnerships between individuals, companies, and institutions. As recently highlighted by the Singapore Ministry of Foreign Affairs, the two countries have established an all-around cooperative partnership that has progressed with the times. China is Singapore’s largest trade partner, with bilateral trade totaling S$164.3 billion in 2021. It is also the top destination for foreign investment originating in Singapore.
Apart from trade and investments, Singapore and China have developed close cooperation in a wide range of other areas, such as intellectual property management, education, innovation, and communications, as well as smart city development. The countries continue working on several state-level bilateral cooperation projects including government-to-government initiatives in Suzhou, Tianjin, Guangzhou, and Chongqing, which are briefly described below.

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Overview of Singapore's Bilateral Agreements With China

To promote economic cooperation and trade, Singapore and China have concluded numerous important agreements. Among the most influential, except the Double Tax Avoidance Agreement, are the Free Trade Agreement and the Mutual Recognition Arrangement.
facts about Singapore-China DTAA

Why the China-Singapore Double Tax Treaty?

The DTAA between Singapore and China was a major milestone in the development of Singapore-China bilateral relations. The initial DTAA was signed in 1986. The current version of this agreement was concluded in 2007.

The main purpose of the DTAA serves to relieve the burden of double taxation of income that is earned in one jurisdiction by a resident of the other jurisdiction. The main provisions of the current DTAA are exhaustively covered in the section below.

Scope of the China-Singapore Tax Treaty

The China-Singapore DTAA applies to all residents (individuals and legal entities) of one or both countries. Therefore, if you are a resident of Singapore, China, or both, then you can avail the provisions of this DTAA.

What Taxes Will I Owe Under the China-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 defines the country where the income of a resident of either Singapore or China will be subject to tax. This is important because, by default, the country where the income is taxable will determine the tax rate applicable to the taxpayer’s income if those rates are not explicitly specified in 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 country where the company is managed and controlled.

Permanent establishment profits

Taxed in the country where the PE is situated and carries out its business, but only on the amount attributable to that PE.

Profits from shipping and air transport

Profits derived from the operation of ships and aircraft in international traffic by an enterprise that is resident of a country shall be taxable only in that country.


Taxed in the country where the recipient resides.


Taxed in the country where the recipient resides.


Taxed in the country where the recipient resides.

Capital gains

Taxed in the country where the property is located.

Independent personal services

Taxed in the country where the recipient resides unless he has a fixed base regularly available in the other country for the purpose of performing his or her activities, or his or her stay in the other country is for more than 183 days in any twelve-month period.

Dependent personal services

Taxed in the country where the recipient resides unless the employment is exercised in the other country. However, there are some exceptions.

Directors’ fees

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

Income of artists and sports persons

Taxed in the state where activities are performed.

Pensions and other similar remuneration (including any annuity)

Taxed in the state where the recipient resides.

Government services

Taxed by the government of that country unless the individual is a national of the other country where he or she performs the services.

Payments to students and trainees

Payments that a student or trainee receives for the purpose of his or her maintenance, education or training are not taxed in the country of education (Country A) if:

  • A student or trainee is a resident of the other country (Country B)
  • A student or trainee is present in Country A solely for the purpose of his or her education or training
  • Such payments arise from sources outside of the Country A.
Income that cannot be included in the above-mentioned categories shall be taxable only in the country in which it arises.

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