AGREEMENT BETWEEN THE PRINCIPALITY OF LIECHTENSTEIN AND THE REPUBLIC OF SINGAPORE FOR THE AVOIDANCE OF DOUBLE TAXATION AND

THE PREVENTION OF FISCAL EVASION WITH RESPECT TO TAXES ON INCOME The Principality of Liechtenstein and the Republic of Singapore, Desiring to conclude an Agreement for the Avoidance of Double Taxation and the Prevention of Fiscal vasion !ith respect to Taxes on "ncome, #ave agreed as follo!s$

Article 1 Pers !s C "ere# This Agreement shall apply to persons !ho are residents of one or both of the %ontracting States& Article $ T%&es C "ere# '& This Agreement shall apply to taxes on income imposed on behalf of a %ontracting State or of its political subdivisions or local authorities, irrespective of the manner in !hich they are levied& (& There shall be regarded as taxes on income all taxes imposed on total income, or on elements of income, including taxes on gains from the alienation of movable or immovable property& )& The existing taxes to !hich this Agreement shall apply are in particular$ *a+ in the case of Liechtenstein$ *i+ *ii+ *iii+ *iv+ *v+ *vi+ the personal income tax * r!erbssteuer+, the corporate income tax * rtragssteuer+, the corporation taxes *-esellschaftssteuern+, the real estate capital gains tax *-rundst.c/sge!innsteuer+, the !ealth tax *0erm1genssteuer+, and the coupon tax *%ouponsteuer+,

*hereinafter referred to as 2Liechtenstein tax3+

1

*b+

in the case of Singapore$ *i+ the income tax,

*hereinafter referred to as 2Singapore tax3+ 4& This Agreement shall apply also to any identical or substantially similar taxes that are imposed after the date of signature of this Agreement in addition to, or in place of, the existing taxes& The competent authorities of the %ontracting States shall notify each other of any significant changes that have been made in their taxation la!s& Article ' Ge!er%l De(i!iti !s '& For the purposes of this Agreement, unless the context other!ise re5uires$ *a+ *b+ the terms 2a %ontracting State3 and 2the other %ontracting State3 mean Liechtenstein or Singapore as the context re5uires, the term 2Liechtenstein3 means the Principality of Liechtenstein, and, !hen used in a geographical sense, the area of the sovereign territory of the Principality of Liechtenstein, the term 2Singapore3 means the Republic of Singapore and, !hen used in geographical sense, includes its land territory, internal !aters and territorial sea, as !ell as any maritime area situated beyond the territorial sea !hich has been or might in the future be designated under its national la!, in accordance !ith international la!, as an area !ithin !hich Singapore may exercise sovereign rights or 6urisdiction !ith regards to the sea, the sea7bed, the subsoil and the natural resources, the term 2person3 includes an individual, a company, dormant inheritances and any other body of persons, the term 2company3 means any body corporate, or any entity that is treated as a body corporate for tax purposes, the terms 2enterprise of a %ontracting State3 and 2enterprise of the other %ontracting State3 mean respectively an enterprise carried on by a resident of a %ontracting State and an enterprise carried on by a resident of the other %ontracting State, the term 2international traffic3 means any transport by a ship or aircraft operated by an enterprise of a %ontracting State, except !hen the ship or aircraft is operated solely bet!een places in the other %ontracting State, the term 2competent authority3 means$ *i+ *ii+ *i+ in the case of Liechtenstein, the -overnment of the Principality of Liechtenstein or its authorised representative, in the case of Singapore, the 8inister for Finance or his authorised representative,

*c+

*d+ *e+ *f+

*g+

*h+

the term 2national3 in relation to a %ontracting State, means$

2

*i+ *ii+

any individual possessing the nationality or citi9enship of that %ontracting State, and any legal person, partnership or association deriving its status as such from the la!s in force in that %ontracting State&

(& As regards the application of this Agreement at any time by a %ontracting State, any term not defined therein shall, unless the context other!ise re5uires, have the meaning that it has at that time under the la! of that State for the purposes of the taxes to !hich this Agreement applies, any meaning under the applicable tax la!s of that State prevailing over a meaning given to the term under other la!s of that State& Article ) Resi#e!t '& For the purposes of this Agreement, the term 2resident of a %ontracting State3 means any person !ho, under the la!s of that State, is liable to tax therein by reason of his domicile, residence, place of management or any other criterion of a similar nature and also includes that State and any political subdivision, local authority or statutory body thereof& (& :here by reason of the provisions of paragraph ' an individual is a resident of both %ontracting States, then his status shall be determined as follo!s$ *a+ he shall be deemed to be a resident only of the State in !hich he has a permanent home available to him, if he has a permanent home available to him in both States, he shall be deemed to be a resident only of the State !ith !hich his personal and economic relations are closer *centre of vital interests+, if the State in !hich he has his centre of vital interests cannot be determined, or if he has not a permanent home available to him in either State, he shall be deemed to be a resident only of the State in !hich he has an habitual abode, if he has an habitual abode in both States or in neither of them, he shall be deemed to be a resident only of the State of !hich he is a national, in any other case, the competent authorities of the %ontracting States shall settle the 5uestion by mutual agreement&

*b+

*c+ *d+

)& :here by reason of the provisions of paragraph ' a person other than an individual is a resident of both %ontracting States, then it shall be deemed to be a resident only of the State in !hich its place of effective management is situated& Article * Per+%!e!t Est%,lis-+e!t '& For the purposes of this Agreement, the term 2permanent establishment3 means a fixed place of business through !hich the business of an enterprise is !holly or partly carried on& (& The term 2permanent establishment3 includes especially$ *a+ *b+ a place of management, a branch,

3

*c+ *d+ *e+ *f+ )& *a+ *b+

an office, a factory, a !or/shop, and a mine, an oil or gas !ell, a 5uarry or any other place of extraction of natural resources& A building site or construction or installation pro6ect constitutes a permanent establishment only if it lasts more than t!elve months& The furnishing of services, including consultancy services, by an enterprise of a %ontracting State through employees or other personnel engaged by the enterprise constitutes a permanent establishment only !here activities of that nature continue *for the same or a connected pro6ect+ !ithin the other %ontracting State for a period or periods aggregating more than );< days in any fifteen7month period&

4& =ot!ithstanding the preceding provisions of this Article, the term 2permanent establishment3 shall be deemed not to include$ *a+ *b+ *c+ *d+ *e+ *f+ the use of facilities solely for the purpose of storage, display or delivery of goods or merchandise belonging to the enterprise, the maintenance of a stoc/ of goods or merchandise belonging to the enterprise solely for the purpose of storage, display or delivery, the maintenance of a stoc/ of goods or merchandise belonging to the enterprise solely for the purpose of processing by another enterprise, the maintenance of a fixed place of business solely for the purpose of purchasing goods or merchandise or of collecting information, for the enterprise, the maintenance of a fixed place of business solely for the purpose of carrying on, for the enterprise, any other activity of a preparatory or auxiliary character, the maintenance of a fixed place of business solely for any combination of activities mentioned in subparagraphs *a+ to *e+, provided that the overall activity of the fixed place of business resulting from this combination is of a preparatory or auxiliary character&

<& =ot!ithstanding the provisions of paragraphs ' and (, !here a person > other than an agent of an independent status to !hom paragraph ; applies > is acting on behalf of an enterprise and has, and habitually exercises, in a %ontracting State an authority to conclude contracts in the name of the enterprise, that enterprise shall be deemed to have a permanent establishment in that State in respect of any activities !hich that person underta/es for the enterprise, unless the activities of such person are limited to those mentioned in paragraph 4 !hich, if exercised through a fixed place of business, !ould not ma/e this fixed place of business a permanent establishment under the provisions of that paragraph& ;& An enterprise shall not be deemed to have a permanent establishment in a %ontracting State merely because it carries on business in that State through a bro/er, general commission agent or any other agent of an independent status, provided that such persons are acting in the ordinary course of their business&

4

?& The fact that a company !hich is a resident of a %ontracting State controls or is controlled by a company !hich is a resident of the other %ontracting State, or !hich carries on business in that other State *!hether through a permanent establishment or other!ise+, shall not of itself constitute either company a permanent establishment of the other& Article . I!c +e (r + I++ "%,le Pr /ert0 '& "ncome derived by a resident of a %ontracting State from immovable property *including income from agriculture or forestry+ situated in the other %ontracting State may be taxed in that other State& (& The term 2immovable property3 shall have the meaning !hich it has under the la! of the %ontracting State in !hich the property in 5uestion is situated& The term shall in any case include property accessory to immovable property, livestoc/ and e5uipment used in agriculture and forestry, rights to !hich the provisions of general la! respecting landed property apply, usufruct of immovable property and rights to variable or fixed payments as consideration for the !or/ing of, or the right to !or/, mineral deposits, sources and other natural resources, ships, boats and aircraft shall not be regarded as immovable property& )& The provisions of paragraph ' shall apply to income derived from the direct use, letting, or use in any other form of immovable property& 4& The provisions of paragraphs ' and ) shall also apply to the income from immovable property of an enterprise and to income from immovable property used for the performance of independent personal services& Article 1 B2si!ess Pr (its '& The profits of an enterprise of a %ontracting State shall be taxable only in that State unless the enterprise carries on business in the other %ontracting State through a permanent establishment situated therein& "f the enterprise carries on business as aforesaid, the profits of the enterprise may be taxed in the other State but only so much of them as is attributable to that permanent establishment& (& Sub6ect to the provisions of paragraph ), !here an enterprise of a %ontracting State carries on business in the other %ontracting State through a permanent establishment situated therein, there shall in each %ontracting State be attributed to that permanent establishment the profits !hich it might be expected to ma/e if it !ere a distinct and separate enterprise engaged in the same or similar activities under the same or similar conditions and dealing !holly independently !ith the enterprise of !hich it is a permanent establishment& )& "n determining the profits of a permanent establishment, there shall be allo!ed as deductions expenses !hich are incurred for the purposes of the permanent establishment, including executive and general administrative expenses so incurred, !hether in the State in !hich the permanent establishment is situated or else!here& 4& "nsofar as it has been customary in a %ontracting State to determine the profits to be attributed to a permanent establishment on the basis of an apportionment of the total profits of the enterprise to its various parts, or on the basis of such other method as may be prescribed by the la!s of that State, nothing in paragraph ( shall preclude that %ontracting State from determining the profits to be taxed by such apportionment or other method as

5

may be customary, the method adopted shall, ho!ever, be such that the result shall be in accordance !ith the principles contained in this Article& <& =o profits shall be attributed to a permanent establishment by reason of the mere purchase by that permanent establishment of goods or merchandise for the enterprise& ;& For the purposes of the preceding paragraphs, the profits to be attributed to the permanent establishment shall be determined by the same method year by year unless there is good and sufficient reason to the contrary& ?& :here profits include items of income !hich are dealt !ith separately in other Articles of this Agreement, then the provisions of those Articles shall not be affected by the provisions of this Article& Article 3 S-i//i!4 %!# Air Tr%!s/ rt '& Profits derived by an enterprise of a %ontracting State from the operation of ships or aircraft in international traffic shall be taxable only in that State& (& The provisions of paragraph ' shall also apply to profits from the participation in a pool, a 6oint business or an international operating agency& )& "nterest on funds connected !ith the operations of ships or aircraft in international traffic shall be regarded as profits derived from the operation of such ships or aircraft, and the provisions of Article '' shall not apply in relation to such interest& 4& For the purposes of this Article, profits from the operation of ships or aircraft in international traffic shall include$ *a+ *b+ profits from the rental on a bareboat basis of ships or aircraft, and profits from the use, maintenance or rental of containers *including trailers and related e5uipment for the transport of containers+, used for the transport of goods or merchandise,

!here such rental or such use, maintenance or rental, as the case may be, is incidental to the operation of ships or aircraft in international traffic& Article 5 Ass ci%te# E!ter/rises '& :here *a+ *b+ an enterprise of a %ontracting State participates directly or indirectly in the management, control or capital of an enterprise of the other %ontracting State, or the same persons participate directly or indirectly in the management, control or capital of an enterprise of a %ontracting State and an enterprise of the other %ontracting State,

and in either case conditions are made or imposed bet!een the t!o enterprises in their commercial or financial relations !hich differ from those !hich !ould be made bet!een independent enterprises, then any profits !hich !ould, but for those conditions, have accrued to

6

one of the enterprises, but, by reason of those conditions, have not so accrued, may be included in the profits of that enterprise and taxed accordingly& (& :here a %ontracting State includes in the profits of an enterprise of that State > and taxes accordingly > profits on !hich an enterprise of the other %ontracting State has been charged to tax in that other State and the profits so included are profits !hich !ould have accrued to the enterprise of the first7mentioned State if the conditions made bet!een the t!o enterprises had been those !hich !ould have been made bet!een independent enterprises, then that other State shall ma/e an appropriate ad6ustment to the amount of the tax charged therein on those profits& "n determining such ad6ustment, due regard shall be had to the other provisions of this Agreement and the competent authorities of the %ontracting States shall if necessary consult each other& Article 16 Di"i#e!#s '& Dividends paid by a company !hich is a resident of a %ontracting State to a resident of the other %ontracting State shall be taxable only in that other State& This paragraph shall not affect the taxation of the company in respect of the profits out of !hich the dividends are paid& (& The term 2dividends3 as used in this Article means income from shares, 26ouissance3 shares or 26ouissance3 rights, mining shares, founders@ shares or other rights, not being debt7 claims, participating in profits, as !ell as income from other corporate rights !hich is sub6ected to the same taxation treatment as income from shares by the la!s of the State of !hich the company ma/ing the distribution is a resident& )& The provisions of paragraph ' shall not apply if the beneficial o!ner of the dividends, being a resident of a %ontracting State, carries on business in the other %ontracting State of !hich the company paying the dividends is a resident through a permanent establishment situated therein or performs in that other State independent personal services from a fixed base situated therein, and the holding in respect of !hich the dividends are paid is effectively connected !ith such permanent establishment or fixed base& "n such case the provisions of Article ? or Article '4, as the case may be, shall apply& 4& :here a company !hich is a resident of a %ontracting State derives profits or income from the other %ontracting State, that other State may not impose any tax on the dividends paid by the company, except insofar as such dividends are paid to a resident of that other State or insofar as the holding in respect of !hich the dividends are paid is effectively connected !ith a permanent establishment or a fixed base situated in that other State, nor sub6ect the company@s undistributed profits to a tax on the company@s undistributed profits, even if the dividends paid or the undistributed profits consist !holly or partly of profits or income arising in such other State& Article 11 I!terest '& "nterest arising in a %ontracting State and paid to a resident of the other %ontracting State may be taxed in that other State& (& #o!ever, such interest may also be taxed in the %ontracting State in !hich it arises and according to the la!s of that State, but if the beneficial o!ner of the interest is a resident of the other %ontracting State, the tax so charged shall not exceed '( per cent of the gross amount of the interest&

7

)& =ot!ithstanding the provisions of paragraph (, interest arising in a %ontracting State and paid to the -overnment of the other %ontracting State shall be exempt from tax in the first7mentioned State& 4& For the purpose of paragraph ), the term A-overnmentA$ *a+ in the case of Liechtenstein, means the -overnment of Liechtenstein and shall include$ *i+ *ii+ a statutory body, and any institution !holly or mainly o!ned by the -overnment of Liechtenstein as may be agreed from time to time bet!een the competent authorities of the %ontracting States&

*b+

in the case of Singapore, means the -overnment of Singapore and shall include$ *i+ *ii+ *iii+ *iv+ the 8onetary Authority of Singapore, the -overnment of Singapore "nvestment %orporation Pte Ltd, a statutory body, and any institution !holly or mainly o!ned by the -overnment of Singapore as may be agreed from time to time bet!een the competent authorities of the %ontracting States&

<& The term 2interest3 as used in this Article means income from debt7claims of every /ind, !hether or not secured by mortgage and !hether or not carrying a right to participate in the debtor@s profits, and in particular, income from government securities and income from bonds or debentures, including premiums and pri9es attaching to such securities, bonds or debentures& Penalty charges for late payment shall not be regarded as interest for the purpose of this Article& ;& The provisions of paragraphs ' and ( shall not apply if the beneficial o!ner of the interest, being a resident of a %ontracting State, carries on business in the other %ontracting State in !hich the interest arises, through a permanent establishment situated therein, or performs in that other State independent personal services from a fixed base situated therein, and the debt7claim in respect of !hich the interest is paid is effectively connected !ith such permanent establishment or fixed base& "n such case the provisions of Article ? or Article '4, as the case may be, shall apply& ?& "nterest shall be deemed to arise in a %ontracting State !hen the payer is a resident of that State& :here, ho!ever, the person paying the interest, !hether he is a resident of a %ontracting State or not, has in a %ontracting State a permanent establishment or a fixed base in connection !ith !hich the indebtedness on !hich the interest is paid !as incurred, and such interest is borne by such permanent establishment or fixed base, then such interest shall be deemed to arise in the State in !hich the permanent establishment or fixed base is situated& B& :here, by reason of a special relationship bet!een the payer and the beneficial o!ner or bet!een both of them and some other person, the amount of the interest, having regard to the debt7claim for !hich it is paid, exceeds the amount !hich !ould have been agreed upon by the payer and the beneficial o!ner in the absence of such relationship, the provisions of this Article shall apply only to the last7mentioned amount& "n such case, the excess part of the

8

payments shall remain taxable according to the la!s of each %ontracting State, due regard being had to the other provisions of this Agreement& Article 1$ R 0%lties '& Royalties arising in a %ontracting State and paid to a resident of the other %ontracting State may be taxed in that other State& (& #o!ever, such royalties may also be taxed in the %ontracting State in !hich they arise and according to the la!s of that State, but if the beneficial o!ner of the royalties is a resident of the other %ontracting State, the tax so charged shall not exceed B per cent of the gross amount of the royalties& )& The term 2royalties3 as used in this Article means payments of any /ind received as a consideration for the use of, or the right to use, any copyright of literary, artistic or scientific !or/ including cinematograph films, or films or tapes used for radio or television broadcasting, any computer soft!are, patent, trade mar/, design or model, plan, secret formula or process, or for information concerning industrial, commercial or scientific experience& 4& The provisions of paragraphs ' and ( shall not apply if the beneficial o!ner of the royalties, being a resident of a %ontracting State, carries on business in the other %ontracting State in !hich the royalties arise, through a permanent establishment situated therein, or performs in that other State independent personal services from a fixed base situated therein, and the right or property in respect of !hich the royalties are paid is effectively connected !ith such permanent establishment or fixed base& "n such case, the provisions of Article ? or Article '4, as the case may be, shall apply& <& Royalties shall be deemed to arise in a %ontracting State !hen the payer is a resident of that State& :here, ho!ever, the person paying the royalties, !hether he is a resident of a %ontracting State or not, has in a %ontracting State a permanent establishment or a fixed base in connection !ith !hich the liability to pay the royalties !as incurred, and such royalties are borne by such permanent establishment or fixed base, then such royalties shall be deemed to arise in the State in !hich the permanent establishment or fixed base is situated& ;& :here, by reason of a special relationship bet!een the payer and the beneficial o!ner or bet!een both of them and some other person, the amount of the royalties, having regard to the use, right or information for !hich they are paid, exceeds the amount !hich !ould have been agreed upon by the payer and the beneficial o!ner in the absence of such relationship, the provisions of this Article shall apply only to the last7mentioned amount& "n such case, the excess part of the payments shall remain taxable according to the la!s of each %ontracting State, due regard being had to the other provisions of this Agreement& Article 1' C%/it%l G%i!s '& -ains derived by a resident of a %ontracting State from the alienation of immovable property referred to in Article ; and situated in the other %ontracting State may be taxed in that other State& (& -ains from the alienation of movable property forming part of the business property of a permanent establishment !hich an enterprise of a %ontracting State has in the other

9

%ontracting State or of movable property pertaining to a fixed base available to a resident of a %ontracting State in the other %ontracting State for the purpose of performing independent personal services, including such gains from the alienation of such a permanent establishment *alone or !ith the !hole enterprise+ or of such fixed base, may be taxed in that other State& )& -ains derived by a resident of a %ontracting State from the alienation of ships or aircraft operated in international traffic, or movable property pertaining to the operation of such ships or aircraft, shall be taxable only in that State& 4& -ains from the alienation of any property, other than that referred to in the preceding paragraphs of this Article shall be taxable only in the %ontracting State of !hich the alienator is a resident& Article 1) I!#e/e!#e!t Pers !%l Ser"ices '& "ncome derived by an individual !ho is a resident of a %ontracting State in respect of professional services or other activities of an independent character shall be taxable only in that State except in the follo!ing circumstances, !hen such income may also be taxed in the other %ontracting State$ *a+ if he has a fixed base regularly available to him in the other %ontracting State for the purpose of performing his activities, in that case, only so much of the income as is attributable to that fixed base may be taxed in that other %ontracting State, or if his stay in the other %ontracting State is for a period or periods exceeding in the aggregate );< days in any fifteen7month period, in that case, only so much of the income as is derived from his activities performed in that other State may be taxed in that other State&

*b+

(& The term Aprofessional servicesA includes especially independent scientific, literary, artistic, educational or teaching activities as !ell as the independent activities of physicians, la!yers, engineers, architects, dentists and accountants& Article 1* I!c +e (r + E+/l 0+e!t '& Sub6ect to the provisions of Articles ';, 'B and 'C, salaries, !ages and other similar remuneration derived by a resident of a %ontracting State in respect of an employment shall be taxable only in that State unless the employment is exercised in the other %ontracting State& "f the employment is so exercised, such remuneration as is derived therefrom may be taxed in that other State& (& =ot!ithstanding the provisions of paragraph ', remuneration derived by a resident of a %ontracting State in respect of an employment exercised in the other %ontracting State shall be taxable only in the first7mentioned State if$ *a+ the recipient is present in the other State for a period or periods not exceeding in the aggregate 'B) days in any t!elve7month period commencing or ending in the fiscal year concerned, and the remuneration is paid by, or on behalf of, an employer !ho is not a resident of the other State, and

*b+

10

*c+

the remuneration is not borne by a permanent establishment or a fixed base !hich the employer has in the other State&

)& =ot!ithstanding the preceding provisions of this Article, remuneration derived in respect of an employment exercised aboard a ship or aircraft operated in international traffic by an enterprise of a %ontracting State shall be taxable only in that State& #o!ever, if the remuneration is derived by a resident of the other %ontracting State, it may also be taxed in that other State& Article 1. Direct rs7 Fees DirectorsD fees and other similar payments derived by a resident of a %ontracting State in his capacity as a member of the board of directors of a company or a similar body of a body corporate !hich is a resident of the other %ontracting State, may be taxed in that other State& Article 11 Artistes %!# S/ rts+e! '& =ot!ithstanding the provisions of Articles '4 and '<, income derived by a resident of a %ontracting State as an entertainer, such as a theatre, motion picture, radio or television artiste, or a musician, or as a sportsman, from his personal activities as such exercised in the other %ontracting State, may be taxed in that other State& (& :here income in respect of or in connection !ith personal activities exercised by an entertainer or a sportsman accrues not to the entertainer or sportsman himself but to another person, that income may, not!ithstanding the provisions of Articles ?, '4 and '<, be taxed in the %ontracting State in !hich the activities of the entertainer or sportsman are exercised& )& The provisions of paragraphs ' and ( shall not apply to income derived from activities exercised in a %ontracting State by an artiste or a sportsman if the visit to that State is !holly or mainly supported by public funds of one or both of the %ontracting States or political subdivisions or local authorities or statutory bodies thereof& "n such case, the income shall be taxable only in the %ontracting State in !hich the artiste or the sportsman is a resident& Article 13 Pe!si !s Sub6ect to the provisions of paragraph ( of Article 'C, pensions and other similar remuneration *!hether periodic or lump7sum payments+ paid to a resident of a %ontracting State in consideration of past employment or self7employment shall be taxable only in that State& Article 15 G "er!+e!t Ser"ice '& *a+ Salaries, !ages and other similar remuneration paid by a %ontracting State or a political subdivision or a local authority or a statutory body thereof to an individual in respect of services rendered to that State or subdivision or authority or body shall be taxable only in that State&

11

*b+

#o!ever, such salaries, !ages and other similar remuneration shall be taxable only in the other %ontracting State if the services are rendered in that State and the individual is a resident of that State !ho$ *i+ *ii+ is a national of that State, or did not become a resident of that State solely for the purpose of rendering the services&

(&

*a+

=ot!ithstanding the provisions of paragraph ', pensions and other similar remuneration paid by, or out of funds created by, a %ontracting State or a political subdivision or a local authority or a statutory body thereof to an individual in respect of services rendered to that State or subdivision or authority or body shall be taxable only in that State& #o!ever, such pensions and other similar remuneration shall be taxable only in the other %ontracting State if the individual is a resident of, and a national of, that State&

*b+

)& The provisions of Articles '<, ';, '? and 'B shall apply to salaries, !ages, pensions, and other similar remuneration in respect of services rendered in connection !ith a business carried on by a %ontracting State or a political subdivision or a local authority or a statutory body thereof& Article $6 St2#e!ts Payments !hich a student or business apprentice !ho is or !as immediately before visiting a %ontracting State a resident of the other %ontracting State and !ho is present in the first7mentioned State solely for the purpose of his education or training receives for the purpose of his maintenance, education or training shall not be taxed in that State, provided that such payments arise from sources outside that State&

Article $1 Ot-er I!c +e '& "tems of income of a resident of a %ontracting State, !herever arising, not dealt !ith in the foregoing Articles of this Agreement shall be taxable only in that State& (& The provisions of paragraph ' shall not apply to income, other than income from immovable property as defined in paragraph ( of Article ;, if the recipient of such income, being a resident of a %ontracting State, carries on business in the other %ontracting State through a permanent establishment situated therein, or performs in that other State independent personal services from a fixed base situated therein, and the right or property in respect of !hich the income is paid is effectively connected !ith such permanent establishment or fixed base& "n such case the provisions of Article ? or Article '4, as the case may be, shall apply& )& =ot!ithstanding the provisions of paragraphs ' and (, items of income of a resident of a %ontracting State not dealt !ith in the foregoing Articles of this Agreement and arising in the other %ontracting State may also be taxed in that other State&

12

Article $$ Eli+i!%ti ! ( D 2,le T%&%ti ! '& "n Liechtenstein, double taxation shall be avoided as follo!s$ *a+ :here a resident of Liechtenstein derives income or o!ns capital !hich, in accordance !ith the provisions of this Agreement, may be taxed in Singapore, Liechtenstein shall, sub6ect to the provisions of subparagraphs *b+ and *c+, exempt such income or capital from tax, but may nevertheless, in calculating the amount of tax on the remaining income or capital of such resident, ta/e into account the exempted income or capital& :here a resident of Liechtenstein derives income !hich, in accordance !ith Article '' paragraph (, Article '( paragraph (, Article '), Article '4, Article '<, Article ';, Article '? and Article (' paragraph ) of this Agreement, may be taxed in Singapore, Liechtenstein shall credit against Liechtenstein tax on this income the tax paid in accordance !ith the la!s of Singapore and !ith the provisions of this Agreement& The amount of tax to be credited must not, ho!ever, exceed the Liechtenstein tax due on the income derived from Singapore& "ncome from dividends !ithin the meaning of Article 'E paid by a company that is a resident of Singapore to a company that is a resident of Liechtenstein and that are not deductible in determining the profits of the payor, shall not be taxed in Liechtenstein&

*b+

*c+

(&

"n Singapore, double taxation shall be avoided as follo!s$ :here a resident of Singapore derives income from Liechtenstein !hich, in accordance !ith the provisions of this Agreement, may be taxed in Liechtenstein, Singapore shall, sub6ect to its la!s regarding the allo!ance as a credit against Singapore tax of tax payable in any country other than Singapore, allo! the Liechtenstein tax paid, !hether directly or by deduction, as a credit against the Singapore tax payable on the income of that resident& :here such income is a dividend paid by a company !hich is a resident of Liechtenstein to a resident of Singapore !hich is a company o!ning directly or indirectly not less than 'E per cent of the share capital of the first7mentioned company, the credit shall ta/e into account the Liechtenstein tax paid by that company on the portion of its profits out of !hich the dividend is paid& Article $' N !8Discri+i!%ti !

'& =ationals of a %ontracting State shall not be sub6ected in the other %ontracting State to any taxation or any re5uirement connected there!ith, !hich is other or more burdensome than the taxation and connected re5uirements to !hich nationals of that other State in the same circumstances, in particular !ith respect to residence, are or may be sub6ected& (& The taxation on a permanent establishment !hich an enterprise of a %ontracting State has in the other %ontracting State shall not be less favourably levied in that other State than the taxation levied on enterprises of that other State carrying on the same activities& )& =othing in this Article shall be construed as obliging a %ontracting State to grant to$ *a+ residents of the other %ontracting State any personal allo!ances, reliefs and reductions for tax purposes !hich it grants to its o!n residents, or

13

*b+

nationals of the other %ontracting State those personal allo!ances, reliefs and reductions for tax purposes !hich it grants to its o!n nationals !ho are not residents of that State or to such other persons as may be specified in the taxation la!s of that State&

4& nterprises of a %ontracting State, the capital of !hich is !holly or partly o!ned or controlled, directly or indirectly, by one or more residents of the other %ontracting State, shall not be sub6ected in the first7mentioned State to any taxation or any re5uirement connected there!ith !hich is other or more burdensome than the taxation and connected re5uirements to !hich other similar enterprises of the first7mentioned State are or may be sub6ected& <& :here a %ontracting State grants tax incentives to its nationals designed to promote economic or social development in accordance !ith its national policy and criteria, it shall not be construed as discrimination under this Article& ;& The provisions of this Article shall apply to the taxes !hich are the sub6ect of this Agreement& Article $) M2t2%l A4ree+e!t Pr ce#2re '& :here a person considers that the actions of one or both of the %ontracting States result or !ill result for him in taxation not in accordance !ith the provisions of this Agreement, he may, irrespective of the remedies provided by the domestic la! of those States, present his case to the competent authority of the %ontracting State of !hich he is a resident or, if his case comes under paragraph ' of Article (), to that of the %ontracting State of !hich he is a national& The case must be presented !ithin three years from the first notification of the action resulting in taxation not in accordance !ith the provisions of this Agreement& (& The competent authority shall endeavour, if the ob6ection appears to it to be 6ustified and if it is not itself able to arrive at a satisfactory solution, to resolve the case by mutual agreement !ith the competent authority of the other %ontracting State, !ith a vie! to the avoidance of taxation !hich is not in accordance !ith this Agreement& Any agreement reached shall be implemented not!ithstanding any time limits in the domestic la! of the %ontracting States& )& The competent authorities of the %ontracting States shall endeavour to resolve by mutual agreement any difficulties or doubts arising as to the interpretation or application of this Agreement& They may also consult together for the elimination of double taxation in cases not provided for in this Agreement& 4& The competent authorities of the %ontracting States may communicate !ith each other directly for the purpose of reaching an agreement in the sense of the preceding paragraphs& Article $* E&c-%!4e ( I!( r+%ti ! '& The competent authorities of the %ontracting States shall exchange such information as is foreseeably relevant for carrying out the provisions of this Agreement or to the administration or enforcement of the domestic la!s concerning taxes of every /ind and description imposed on behalf of the %ontracting States, or of their political subdivisions or local authorities, insofar as the taxation thereunder is not contrary to this Agreement& The exchange of information is not restricted by Articles ' and (&

14

(& Any information received under paragraph ' by a %ontracting State shall be treated as secret in the same manner as information obtained under the domestic la!s of that State and shall be disclosed only to persons or authorities *including courts and administrative bodies+ concerned !ith the assessment or collection of, the enforcement or prosecution in respect of, the determination of appeals in relation to the taxes referred to in paragraph ', or the oversight of the above& Such persons or authorities shall use the information only for such purposes& They may disclose the information in public court proceedings or in 6udicial decisions& )& "n no case shall the provisions of paragraphs ' and ( be construed so as to impose on a %ontracting State the obligation$ *a+ *b+ *c+ to carry out administrative measures at variance !ith the la!s and administrative practice of that or of the other %ontracting State, to supply information !hich is not obtainable under the la!s or in the normal course of the administration of that or of the other %ontracting State, to supply information !hich !ould disclose any trade, business, industrial, commercial or professional secret or trade process, or information the disclosure of !hich !ould be contrary to public policy *ordre public+&

4& "f information is re5uested by a %ontracting State in accordance !ith this Article, the other %ontracting State shall use its information gathering measures to obtain the re5uested information, even though that other State may not need such information for its o!n tax purposes& The obligation contained in the preceding sentence is sub6ect to the limitations of paragraph ) but in no case shall such limitations be construed to permit a %ontracting State to decline to supply information solely because it has no domestic interest in such information& <& "n no case shall the provisions of paragraph ) be construed to permit a %ontracting State to decline to supply information solely because the information is held by a ban/, other financial institution, nominee or person acting in an agency or a fiduciary capacity or because it relates to o!nership interests in a person& Article $. Me+,ers ( Di/l +%tic Missi !s %!# C !s2l%r P sts =othing in this Agreement shall affect the fiscal privileges of members of diplomatic missions or consular posts under the general rules of international la! or under the provisions of special agreements& Article $1 E!tr0 i!t F rce '& ach of the %ontracting States shall notify to the other in !riting, through diplomatic channels, the completion of the procedures re5uired by its la! for the bringing into force of this Agreement& (& This Agreement shall enter into force on the date of the later of these notifications and its provisions shall have effect$ *a+ in Liechtenstein$

15

*i+

in respect of taxes !ithheld at source, to income derived on or after ' Fanuary of the calendar year next follo!ing the year in !hich this Agreement enters into force, and in respect of other taxes on income and taxes on capital, to taxes chargeable for any taxable year beginning on or after ' Fanuary of the calendar year next follo!ing the year in !hich this Agreement enters into force&

*ii+

*b+

in Singapore$ in respect of tax chargeable for any year of assessment beginning on or after ' Fanuary in the second calendar year follo!ing the year in !hich this Agreement enters into force&

*c+

in Liechtenstein and in Singapore$ in respect of Article (<, for re5uests made on or after the date of entry into force concerning information for taxes relating to taxable periods beginning on or after ' Fanuary of the calendar year next follo!ing the date on !hich this Agreement enters into force, or !here there is no taxable period, for all charges to tax arising on or after ' Fanuary of the calendar year next follo!ing the date on !hich this Agreement enters into force& Article $3 Ter+i!%ti !

This Agreement shall remain in force until terminated by a %ontracting State& ither %ontracting State may terminate this Agreement, through diplomatic channels, by giving notice of termination at least six months before the end of any calendar year after the expiration of a period of five years from the date of its entry into force& "n such event, this Agreement shall cease to have effect$ *a+ in Liechtenstein$ *i+ in respect of taxes !ithheld at source, to income derived on or after ' Fanuary of the calendar year next follo!ing the year in !hich the notice is given, in respect of other taxes on income and taxes on capital, to taxes chargeable for any taxable year beginning on or after ' Fanuary of the calendar year next follo!ing the year in !hich the notice is given, and in all other cases, after the end of that calendar year in !hich the notice of termination is given&

*ii+

*iii+ *b+

in Singapore$ *i+ in respect of tax chargeable for any year of assessment beginning on or after ' Fanuary in the second calendar year follo!ing the year in !hich the notice is given, and in all other cases, after the end of that calendar year in !hich the notice of termination is given&

*ii+

16

"= :"T= SS :# R GF the undersigned, duly authorised thereto, have signed this Agreement&

DG= in duplicate at Singapore on this (?th day of Fune (E') in the nglish and -erman languages, both texts being e5ually authentic& "n case of any divergence of interpretation or application of this Agreement, the nglish text shall prevail&

F r t-e Pri!ci/%lit0 ( Liec-te!stei!

F r t-e Re/2,lic ( Si!4%/ re

&&&&&&&&&&&&&&&&&&&&&&&&&&&&&&&&&&&&&&&&&&

&&&&&&&&&&&&&&&&&&&&&&&&&&&&&&&&&&&&&&&&&&

17

Pr t c l At the moment of signing the Agreement bet!een the Principality of Liechtenstein and the Republic of Singapore for the Avoidance of Double Taxation and the Prevention of Fiscal vasion !ith respect to Taxes on "ncome *hereinafter referred to as 2this Agreement3+, the undersigned have agreed upon the follo!ing provisions, !hich shall form an integral part of this Agreement$ '& :ith respect to Article (<, it is understood that$

*a+ The competent authority of the applicant State shall provide the follo!ing information to the competent authority of the re5uested State !hen ma/ing a re5uest for information in !riting under this Agreement$ *i+ *ii+ *iii+ the identity of the person under examination or investigation, the taxable period !ith respect to !hich the information is re5uested, a statement of the information sought including its nature and the form in !hich the applicant State !ishes to receive the information from the re5uested State, the tax purpose for !hich the information is sought, grounds for believing that the information re5uested is held in the re5uested State or is in the possession or control of a person !ithin the 6urisdiction of the re5uested State, to the extent /no!n, the name and address of any person believed to be in possession of the re5uested information,

*iv+ *v+

*vi+

*vii+ a statement that the applicant State has pursued all means available in its o!n territory to obtain the information, except those that !ould give rise to disproportionate difficulties, and *viii+ a statement that the re5uest is in conformity !ith the la! and administrative practices of the applicant State, that if the re5uested information !as !ithin the 6urisdiction of the applicant State then the competent authority of the applicant State !ould be able to obtain the information under the la!s of the applicant State or in the normal course of administrative practice and that it is in conformity !ith this Agreement& *b+ "t is understood that Article (< does not re5uire the %ontracting States to exchange information on a spontaneous or automatic basis& (& :ith reference to this Agreement, it is understood that the term 2statutory body3 means a body constituted by any statute of a %ontracting State or political subdivision or local authority thereof, and performing non7commercial functions !hich !ould other!ise be performed by the -overnment of a %ontracting State&

18

"= :"T= SS :# R GF the undersigned, duly authorised thereto, have signed this Protocol&

DG= in duplicate at Singapore on this (?th day of Fune (E') in the nglish and -erman languages, both texts being e5ually authentic& "n case of any divergence of interpretation or application of this Protocol, the nglish text shall prevail&

F r t-e Pri!ci/%lit0 ( Liec-te!stei!

F r t-e Re/2,lic ( Si!4%/ re

&&&&&&&&&&&&&&&&&&&&&&&&&&&&&&&&&&&&&&&&&&

&&&&&&&&&&&&&&&&&&&&&&&&&&&&&&&&&&&&&&&&&&

19