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  • Service: Tax, International Tax
  • Type: Regulatory update
  • Date: 11/22/2013

Singapore - Exchange of information requests filed by treaty partners 

November 22:  The Singapore High Court recently released two judgments involving requests of the Comptroller of Income Tax for orders directing Singapore banks to release tax information per the request of two tax treaty partner countries—India and Japan. The applications were made pursuant to exchange of information (EOI) requests by the Indian and Japanese tax authorities.
  • Comptroller of Income Tax v. BJY - The High Court concluded that it was justified to “made the order” for certain specified information to be produced by banks in Singapore to the Comptroller, following an EOI request from the Competent Authority of India, on the basis that the taxpayer: (1) had permanent establishments in India; (2) received monies from these Indian permanent establishments into bank accounts with the Singapore banks; and (3) such monies had not been subject to tax in India.
  • Comptroller of Income Tax v. BLM - The High Court dismissed an application filed by bank account holders, to stay or discharge an order granted in May 2013 authorizing the Inland Revenue Authority of Singapore to disclose various bank statements to the National Tax Agency of Japan.

Read a November 2013 report prepared by the KPMG member firm in Singapore: Tax Alert (November 2013)




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