The tax treaty between Singapore and Nigeria will enter into force on November 1, 2018, and will take effect on January 1, 2019.
Place of effective management
Under the tax treaty, case of dual-residence conflicts (for businesses) shall be settled using the “place of effective management” test. If a company’s place of effective management cannot be determined, the same will be settled by mutual agreement.
Service permanent establishment
The tax treaty includes in the definition of “permanent establishment” furnishing of services, including consultancy services through employees or other personnel engaged for such purpose, but only if activities of that nature continue (for the same or a connected project) for a period or periods aggregating more than 183 days in any 12-month period.
The tax treaty provides for a low withholding tax rate of 7.5 percent for dividend, interest, and royalty income.
Exchange of information
Finally, a detailed Article to facilitate exchange of tax information between both countries is included in the tax treaty.