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2021年2月21日发(作者：主题乐园策划)

THE THIRD PROTOCOL TO THE AGREEMENT BETWEEN

THE GOVERNMENT OF THE

PEOPLE’S

REPUBLIC OF CHINA

AND

THE GOVERNMENT OF THE REPUBLIC OF SINGAPORE

FOR THE AVOIDANCE OF DOUBLE TAXATION AND

THE PREVENTION OF FISCAL EVASION

WITH RESPECT TO TAXES ON INCOME

T

he

Government

of

the

People’s

Republic

of

China

and

the

Government

of

the

Republic of Singapore,

Having regard to the Agreement between the Government of the

People’s

Republic of

China and the Government of the Republic of Singapore for the Avoidance of Double

Taxation

and

the

Prevention

of

Fiscal

Evasion

with

respect

to

Taxes

on

Income,

signed

at

Singapore

on

11

th

day

of

July

2007

(hereinafter

referred

to

as

“the

A

greement”),

Have

agreed

that

the

following

provisions

shall

form

an

integral

part

of

the

Agreement:

Article 1

With respect to Article 25 of the Agreement, paragraphs 1, 2 and 3 shall be deleted

and replaced by the following:

“1.

The

competent

authorities

of

the

Contracting

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 laws concerning

t

axes

of

every

kind

and

description

imposed

on

behalf

of

the

Contracting

States

or

l

ocal authorities, insofar as the taxation thereunder is not contrary to the Agreement.

T

he exchange of information is not restricted by Articles 1 and 2.

2.

Any information received under paragraph 1 by a Contracting State shall be treated

as secret in the same manner as information obtained under the domestic laws of that

State

and

shall

be

disclosed

only

to

persons

or

authorities

(including

courts

and

administrative

bodies)

concerned

with

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

1,

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 judicial decisions.

3.

In no case shall the provisions of paragraphs 1 and 2 be construed so as to impose

on a Contracting State the obligation:

a)

to carry out administrative measures at variance with the laws and administrative

practice of that or of the other Contracting State;

b)

to

supply

information

which

is

not

obtainable

under

the

laws

or

in

the

normal

course of the administration of that or of the other Contracting State;

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