DoubleTaxationSingapore – Japan tax treaty: residence, 183 days, rates
Agreement between the Government of the Republic of Singapore and the Government of Japan for the avoidance of double taxation and the prevention of fiscal evasion with respect to taxes on income (signed at Singapore on 9 April 1994), with Protocol and Exchange of Notes, as amended by the Protocol of 4 February 2010 and modified by the MLI
- Signed: 09/04/1994
- In force since: 28/04/1995
- Official text
If both countries treat you as resident
- A dual-resident individual is deemed to be a resident of the State with which his personal and economic relations are closest (centre of vital interests). The Agreement has no permanent-home test. Art. 4(2)(a) of the Singapore–Japan Agreement
- If the State in which he has his centre of vital interests cannot be determined, he is deemed to be a resident of the State in which he has an habitual abode. Art. 4(2)(b) of the Singapore–Japan 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–Japan 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 any 12-month period. | Art. 7, Art. 14 |
| Pension | Only the country of residence. | Art. 18 |
| 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 15%; the country of residence relieves double taxation. | Art. 10(2)(b) |
| Interest (deposits, bonds, loans) | Source country: at most 10%; the country of residence relieves double taxation. Other rates or exemptions apply in some cases (see the article). | Art. 11(2) |
| Royalties (copyright, licences) | Source country: at most 10%; 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 from real estate: the same. Other property: under certain conditions the source country may also tax (see the article). | Art. 13 |
| Other income | The source country may tax; the country of residence relieves double taxation. | Art. 21(3) |
How double taxation is relieved
- Japan: credit for the tax paid in the source country, up to the country’s own tax on that income Art. 23(1)
- Singapore: credit for the tax paid in the source country, up to the country’s own tax on that income Art. 23(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.