DoubleTaxationSingapore – United Kingdom tax treaty: residence, 183 days, rates
Agreement between the Government of the Republic of Singapore and the Government of the United Kingdom of Great Britain and Northern Ireland for the avoidance of double taxation and the prevention of fiscal evasion with respect to taxes on income and capital gains (signed at Singapore on 12 February 1997), as amended by the Protocols of 24 August 2009 and 15 February 2012 and modified by the MLI
- Signed: 12/02/1997
- In force since: 19/12/1997
- 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–United Kingdom 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–United Kingdom Agreement
- If he has an habitual abode in both States or in neither, he is deemed to be a resident only 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–United Kingdom 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 only taxes profits of a permanent establishment (fixed base) there. | Art. 7, Art. 14 |
| Pension | Only the country of residence. | Art. 18(1) |
| State pension (social security) | Only the country of residence. | 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 | Only the country of residence. Other rates or exemptions apply in some cases (see the article). | Art. 10(1)-(2) (as replaced by the 2012 Protocol) |
| Interest (deposits, bonds, loans) | Source country: at most 5%; the country of residence relieves double taxation. Other rates or exemptions apply in some cases (see the article). | Art. 11(2) (as replaced by the 2012 Protocol) |
| Royalties (copyright, licences) | Source country: at most 8%; the country of residence relieves double taxation. | Art. 12(2) (as replaced by the 2012 Protocol) |
| 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. 22(1) |
How double taxation is relieved
- United Kingdom: credit for the tax paid in the source country, up to the country’s own tax on that income Art. 23(1) (as replaced by the 2012 Protocol)
- Singapore: credit for the tax paid in the source country, up to the country’s own tax on that income Art. 23(2) (as replaced by the 2012 Protocol)
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.