International Taxation - DTAA - India and Singapore


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An Indian resident received director remuneration from a Singaporean company, with tax already paid in Singapore. The discussion clarifies that under Article 16 of the India-Singapore DTAA, director remuneration is taxed where the paying company resides (Singapore). Therefore, the remuneration is taxable in India, but the tax paid in Singapore can be claimed as a foreign tax credit.

29 July 2022 Mr.A is an Indian Ordinary Resident for the A.Y 2022-23 as per Income tax rules.

He derives Director Remuneration from a company in Singapore. It is taxed in Singapore and taxes paid in Singapore.

As per article 16 of the DTAA between India and Singapore, director remuneration is taxed in the state where the company paying the director fees resides i.e Singapore.

Then, which of the following is correct

1) Is the Director remuneration from Singapore is exempted from taxation in India in hands of Mr. A?

2) If it is taxable in India in the hands of Mr.A and tax paid in Singapore shall be claimed as foreign tax credit in India?

Can anyone help me on the above issue. Thanks in advance

29 July 2022 As per my opinion second option is true.

31 July 2022 Yes, it's taxable in India and relief for tax paid in Singapore can be claimed.


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