2. In paragraph 3, when a stable establishment company operates in the other contracting state through an establishment established on it, the profits it must make are charged in each contracting state when it is a self-sustaining and autonomous enterprise that carries out the same or similar activities under identical or similar conditions and is totally independent of the company whose business is a stable establishment. In any event, where the level of profit that may be associated with a stable institution is not able to be recognized or where it poses exceptional difficulties, the benefits that can be reported to the institution can be estimated on a reasonable basis. Dividends Prior to April 1, 2020, India did not apply withholding tax on dividends. However, the dividend company bears a dividend distribution tax (DDT) of 15% (plus surtax and tax) when the dividend is distributed to its shareholders. The beneficiary shareholder is exempt from paying a dividend tax. So today, shareholders in India do not pay tax on dividends, but the company pays tax. Income that is not expressly mentioned in the previous articles of this Convention may be taxed under the tax legislation of each contracting state. 4. The term “dividends” used in this article refers to income from shares or other rights other than claims on profits and income from other corporate rights that are established under the law of the state in which the company is distributed are subject to the same tax treatment as the income of the shares.
3. Articles 15, 16 and 19 apply to allowances and pensions for services provided in connection with an activity carried out by a contracting state or a political sub-direction or a local authority or legal body. The Convention on the Prevention of Double Taxation (DBA) between Singapore and India came into force in 1994. The provisions of this agreement were amended by a protocol signed on 29 June 2005. The second protocol was signed on June 24, 2011 and came into effect on September 1, 2011. The DBA agreement eliminates double taxation of income between Singapore and India and reduces the overall tax burden on residents of both countries. This article contains a brief analysis of the DBA (DTA) between Singapore and India. Keep in mind that the information provided is only used to provide general advice and is not intended to replace professional advice. A DBA between Singapore and another jurisdiction is intended to avoid double taxation of income collected by a resident of the other jurisdiction in a jurisdiction.