House of Representatives

International Tax Agreements Amendment Bill (No. 2) 2010

Explanatory Memorandum

Circulated by the authority of the Deputy Prime Minister and Treasurer, the Hon Wayne Swan MP

General outline and financial impact

The Second Protocol with Singapore

This Bill amends the International Tax Agreements Act 1953 (Agreements Act 1953) to give the force of law in Australia to a Second Protocol amending the Agreement between the Government of the Commonwealth of Australia 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 Canberra on 11 February 1969 as amended by the Protocol signed at Canberra on 16 October 1989 (Second Protocol), which amends the existing tax treaty with Singapore - the Agreement between the Government of the Commonwealth of Australia 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 Canberra on 11 February 1969 as amended by the Protocol signed at Canberra on 16 October 1989 (existing Agreement).

Date of effect: On the date of entry into force of the Second Protocol. For entry into force, Australia and Singapore are required to provide notification on the completion of the necessary domestic procedures.

Proposal announced: This measure was announced in the then Assistant Treasurer's Media Release No. 047 of 8 September 2009.

Financial impact: Treasury has estimated the revenue impact of the Second Protocol, which upgrades the Exchange of Information Article in the Tax Treaty, as unquantifiable. However, since the Article seeks to expand the scope of taxpayer information available to the Commissioner of Taxation, the proposal is expected to improve taxpayer compliance and increase tax revenue.

Compliance cost impact: In terms of the compliance costs, this proposal is expected to result in a low overall compliance cost impact, comprised of a low implementation impact and no change in ongoing compliance costs relative to the affected group.


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