Singapore-New Zealand 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”)

29 Nov 2024

On 18 and 21 November 2024, the competent authorities of the Republic of Singapore and of New Zealand 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-New Zealand DTA which is available on the Inland Revenue Authority of Singapore’s website here.

INLAND REVENUE AUTHORITY OF SINGAPORE

29 November 2024