DoubleTaxationSingapore – Germany tax treaty: residence, 183 days, rates
Agreement between the Republic of Singapore and the Federal Republic of Germany for the avoidance of double taxation with respect to taxes on income and on capital (signed at Singapore on 28 June 2004), with Protocol, as amended by the Protocol of 9 December 2019
- Signed: 28/06/2004
- In force since: 12/12/2006
- 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–Germany 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–Germany 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); in any other case the competent authorities settle the question by mutual agreement (d). Art. 4(2)(c), (d) of the Singapore–Germany 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. 15(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 the calendar year. | Art. 7, Art. 14 |
| Pension | Only the country of residence. | Art. 18(1) |
| State pension (social security) | Only the source country (for pensions, the paying country). | Art. 18(1) |
| Government service | Usually only the paying country; exception: service in the other country by its national. | Art. 19(1)-(2) |
| Government service pension | Usually only the paying country; exception: service in the other country by its national. | Art. 19(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 10%; the country of residence relieves double taxation. Other rates or exemptions apply in some cases (see the article). | Art. 10(2)(b) |
| Interest (deposits, bonds, loans) | Only the country of residence. | Art. 11(1) |
| Royalties (copyright, licences) | Source country: at most 5%; the country of residence relieves double taxation. | Art. 12(2) |
| Sale of property or shares | Real estate: the country where it is located may tax. Shares of companies deriving their value mainly (over 75%) from real estate: the same. Other property: under certain conditions the source country may also tax (see the article). | Art. 13 |
| Other income | Only the country of residence. | Art. 21(1) |
How double taxation is relieved
- Germany: exemption: the income is not taxed but counts towards the rate on other income (credit for dividends, interest, royalties, gains on sale, director’s fees, performance 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.