DoubleTaxationSingapore – Brazil tax treaty: residence, 183 days, rates
Agreement between the Republic of Singapore and the Federative Republic of Brazil for the Elimination of Double Taxation with respect to Taxes on Income and the Prevention of Tax Evasion and Avoidance, with Protocol, signed at Singapore on 7 May 2018, as amended by the Protocol signed at Brasília on 17 April 2023
- Signed: 07/05/2018
- In force since: 01/12/2021
- Official text
If both countries treat you as resident
- A dual-resident individual is deemed to be a resident of the State in which he has a permanent home available to him; if he has a permanent home available in both States, of the State with which his personal and economic relations are closer (centre of vital interests). Art. 4(2)(a) of the Singapore–Brazil Agreement
- If the State of the centre of vital interests cannot be determined, or if he has no permanent home available in either State, he is deemed to be a resident of the State in which he has an habitual abode. Art. 4(2)(b) of the Singapore–Brazil Agreement
- If he has an habitual abode in both States or in neither, he is deemed to be a resident of the State of which he is a national (c); if he is a national of both States or of neither, the competent authorities settle the question by mutual agreement (d). Art. 4(2)(c), (d) of the Singapore–Brazil Agreement
Income: who taxes it
| Income | Treaty rule | Article |
|---|---|---|
| Salary (employment) | The country where the work is done may tax it. Exempt if all apply: no more than 183 days in any 12-month period; the employer is not resident there; the pay is not borne by its permanent establishment there. | Art. 16(2) |
| Self-employment, business, services | Country of residence; the other country taxes profits of a permanent establishment (fixed base) there, or if your stay there reaches 183 days in any 12-month period. | Art. 7, Art. 15 |
| Pension | Only the source country (for pensions, the paying country). | Art. 19 |
| Government service | Usually only the paying country; exception: service in the other country by its national. | Art. 20(1)-(2) |
| Government service pension | Usually only the paying country; exception: service in the other country by its national. | Art. 20(1)-(2) |
| Rent from real estate | The country where the property is located may tax; the country of residence relieves double taxation. | Art. 6(1) |
| Dividends | Source country: at most 15%; the country of residence relieves double taxation. | Art. 10(2)(b) |
| Interest (deposits, bonds, loans) | Source country: at most 15%; the country of residence relieves double taxation. Other rates or exemptions apply in some cases (see the article). | Art. 11(2)(b) |
| Royalties (copyright, licences) | Source country: at most 10%; the country of residence relieves double taxation. Other rates or exemptions apply in some cases (see the article). | Art. 12(2)(b) |
| Technical, consulting, management services | Source country: at most 10%; the country of residence relieves double taxation. | Art. 13(2) |
| Sale of property or shares | Real estate: the country where it is located may tax. Shares of companies deriving their value mainly (over 50%) from real estate: the same. Other property: under certain conditions the source country may also tax (see the article). | Art. 14 |
| Other income | The source country may tax; the country of residence relieves double taxation. | Art. 23(3) |
How double taxation is relieved
- Brazil: credit for the tax paid in the source country, up to the country’s own tax on that income Art. 24(1)
- Singapore: credit for the tax paid in the source country, up to the country’s own tax on that income Art. 24(2)
Data checked: 10/11/2026. A short summary for individuals; the full conditions, exceptions and protocols are in the treaty text. General information, not legal advice.