Detailed Consulting assignment completed for Investment by Indian Company in Singapore, Malaysia, Sri Lanka for its business projects

Investment by Indian Company in Singapore, Malaysia, Sri Lanka

Study included the study on relevant DTAA

Study included study on websites of relevant Country’s own Income tax department sites ( IRS  / commercial tax dept etc)

Study on websites of other consultants in the line

study of RBI master circulars in this regard

and Study of Pro’s and Con’s of the Specific situation

DTAA Thailand and Singapore

Source : Singapore Govt Income tax dept website

https://www.iras.gov.sg/media/docs/default-source/dtas/singapore-thailand-dta-(ratified)(mli)(1-july-2022).pdf?sfvrsn=9cadbc65_6

Means = Zero tax in home country – Singapore
And pay tax as applicable in Thailand only

Point 3 Means = this includes the “letting” income = Rental income

( same treatment as in India)
Agreement for avoidance of double taxation of income with USA

ARTICLE 6 in India – USA DTAA
INCOME FROM IMMOVABLE PROPERTY (REAL PROPERTY)
1. Income derived by a resident of a Contracting State from immovable property (real property), including income from agriculture or forestry, situated in the other Contracting State may be taxed in that other State.
2. The term “immovable property” shall have the meaning which it has under the law of the Contracting State in which the property in question is situated.
3. The provisions of paragraph 1 shall also apply to income derived from the direct use, letting, or use in any other form of immovable property.
4. The provisions of paragraphs 1 and 3 shall also apply to the income from immovable property of an enterprise and to income from immovable property used for the performance of independent personal services.

Means = Zero tax in home country – Singapore
And pay tax as applicable in Thailand only.

Means
Will have to file ITR in Thailand regularly

Article 22 Means =
Singapore shall allow the credit of TDS in Thailand
Good
( same treatment as in India)

Second source : a private site

Taxed in state, where the property is situated