Treaty detail
Japan - Singapore tax treaty
A practical treaty page built around the official treaty text, key withholding categories, permanent-establishment rules, and article-level summaries.
Signed
1994-04-09
Effective
1995-04-28
Articles seeded
6
Withholding snapshot
Dividends
Individual rate: 15% · Corporate rate: 5%
The lower 5 percent corporate rate generally depends on direct-ownership thresholds under the treaty as amended.
Interest
Rate: 10%
The 10 percent ceiling can be reduced for qualifying government and bank interest.
Royalties
Rate: 10%
Royalties generally face a 10 percent ceiling under the treaty as amended.
Permanent establishment
Construction threshold: more than 6 months
Dependent-agent analysis follows the treaty wording as amended by protocol.
Other treaty flags
Pension treatment is article-specific. Singapore's CPF interacts in distinctive ways with the treaty's pension provisions.
Seeded article summaries
Article 4
Residence
Defines treaty residence under the 1994 wording as amended.
Article 4 reflects modern OECD-aligned provisions as amended by the 2010 protocol.
Article 5
Permanent Establishment
Sets the business-presence threshold including service-PE rules.
The treaty includes both construction and service-PE rules.
Article 7
Business Profits
Generally reserves business profits to the residence state in the absence of a PE.
Article 7 follows OECD-aligned profit-attribution principles.
Article 10
Dividends
Caps source-country dividend withholding at treaty ceilings.
Article 10 produces the 15 percent and 5 percent treaty ceilings.
Article 11
Interest
Limits source-country withholding on qualifying interest.
Article 11 produces a 10 percent ceiling with carve-outs for qualifying government and bank interest.
Article 12
Royalties
Caps royalties at a 10 percent ceiling.
Article 12 limits royalties at 10 percent across the core categories.
Official text
Other treaties involving these jurisdictions
Computed from the cross-reference graph. Links open the related entity on this site.
This entry cites
- TreatyUS–JP treaty
- TreatyGB–JP treaty
- TreatyGB–SG treaty
- TreatyCA–JP treaty
- TreatyAU–JP treaty
- TreatyAU–SG treaty
- TreatyDE–JP treaty
- TreatyDE–SG treaty
Primary sources
- Japan MOF: tax conventionsVerified 2026-05-20
- IRAS: list of DTAsVerified 2026-05-20
- OECD MLI matching databaseVerified 2026-05-20
Important disclaimer
This library is for general tax education only. Always verify filing obligations, due dates, and tax consequences against the cited primary source or with a qualified tax professional.