Singapore-Japan competent authority arrangement on the mode of application of Part VI (Arbitration) of the Multilateral Convention to Implement Tax Treaty Related Measures to Prevent Base Erosion and Profit Shifting (“MLI”)

On 10 June 2022, the competent authorities of the Republic of Singapore and of Japan signed a competent authority arrangement (“CAA”) to establish the mode of application of the arbitration proceedings provided for in Part VI (Arbitration) of the MLI.
The arbitration provisions allow taxpayers to request for issues arising from a Mutual Agreement Procedure case which remained unresolved after a two-year time period to be submitted to an arbitration panel for resolution.
The full text of the CAA is published as Annex B to the Singapore-Japan DTA which is available on the Inland Revenue Authority of Singapore’s website here.

INLAND REVENUE AUTHORITY OF SINGAPORE

16 June 2022