Singapore - Dividend

Article 10. Dividends

1.  Dividends paid by a company which is a resident of one of the States to a resident of the other State may he taxed in that other State. 

2.  However, dividends paid by a company which is a resident of the Netherlands to a resident of Singapore may be taxed in the Netherlands, and according to Netherlands law, but the tax so charged shall not exceed 15 percent of the gross amount of the dividends. Where, however, the recipient of the dividends is a company the capital of which is wholly or partly divided into shares and which holds directly or indirectly at least 25 per cent of the capital of the company paying the dividends, the Netherlands shall not levy a tax on the dividends. 

3.  Dividends paid by a company which is a resident of Singapore to a resident of the Netherlands shall be exempt from any tax in Singapore which is chargeable on dividends in addition to the tax chargeable in respect of the profits of the company. Provided that nothing in this paragraph shall affect the provisions of Singapore law under which the tax in respect of a dividend paid by a company which is a resident of Singapore from which Singapore tax has been, or has been deemed to be, deducted may be adjusted by reference to the rate of tax appropriate to the Singapore year of assessment immediately following that in which the dividend was paid. 

4.  The provisions of paragraph 2 shall not affect the taxation of the company in respect of the profits out of which the dividends are paid. 

5.  The term "dividends" as used in this Article means income from shares, "jouissance" shares or "jouissance" rights, mining shares, founders' shares or other rights, not being debt-claims, participating in profits, as well as income from other corporate rights assimilated to income from shares by the taxation law of the State of which the company making the distribution is a resident. 

6.  The provisions of paragraphs 1, 2 and 3 shall not apply if the recipient of the dividends, being a resident of one of the States, has in the other State, of which the company paying the dividends is a resident, a permanent establishment with which the holding by virtue of which the dividends are paid is effectively connected. In such a case, the provisions of Article 7 shall apply. 

7.  Where a company which is a resident of one of the States derives profits or income from the other State, that other State may not impose any tax on the dividends paid by the company to persons who are not residents of that other State, or subject the company's undistributed profits to a tax on undistributed profits, even if the dividends paid or the undistributed profits consist wholly or partly of profits or income arising in such other State. 

8.  If the system of taxation applicable in either of the States to the profits and distributions of companies is substantially altered the competent authorities may consult each other in order to determine whether it is necessary for this reason to amend the provisions of paragraphs 1, 2 and 3 of this Article. 

Protocol:

II. Ad Articles 10 and 11

Applications for the restitution of tax levied contrary to the provisions of Articles 10 and 11 have to be lodged with the authority
concerned of the State having levied the tax within a period of three years after the expiration of the calendar year in which the tax
has been levied.