Dta Agreement With France
Interest received in a Contracting State and paid to a State established in the other Contracting State may be taxed in that other State. However, such interest may also be taxed in the Contracting State in which it is received if the recipient is the beneficial owner of the interest. The tax thus collected must not exceed 10% of the gross amount. The Government of a Contracting State and certain public entities shall be exempt from tax in the other State Party in respect of interest arising in that other State. Interest paid in a State Party on loans and bonds to an enterprise operating in that State to an enterprise established in another Contracting State shall be exempt from the tax of that first-mentioned Contracting State. These enterprises must be approved by the competent authority and the industrial enterprise includes manufacturing, assembly, processing, construction and civil engineering, shipbuilding, breaking & water supply, energy and water supply, mining and mining, plantations, agriculture, fishing and forestry and other enterprises declared industrial enterprises. The above provisions shall not apply where the beneficial owner of the interest has an MOU or a fixed base in the Contracting State in which the payer is established and the interest paid is effectively linked to that MOU or to the fixed base. Where interest is charged in the Contracting State in which the payer is established, the provisions shall not apply. However, where the payer has an MOU in the other Contracting State in which the beneficial owner is established and interest on a debt related to this MOU is paid, the interest shall be treated as interest in the other Contracting State.
If the interest paid exceeds the amount that would otherwise have been paid, the provision of the treaty shall apply only to that amount and any amount of interest overpaid shall be taxable under the laws of each Contracting State. It should be noted that in the absence of the DBA, foreigners who receive interest from Singapore residents are subject to a withholding tax of 15%. However, France does not collect a withholding tax on interest paid to non-residents. The countries with which France has double taxation (ASA) conventions are listed below: students and trainees residing in one Contracting State just before the visit of the other Contracting State, where they are temporarily staying as students at a recognised university or similar institutions or as grant recipients, subsidies or subsidies from the government, non-profit, religious or similar organizations or apprentices of the entrepreneur s exempt from tax in the other State on all transfers and subsidies from abroad and any remuneration for services provided in that other State, provided that the services are provided for the purposes that supplement its available resources for its maintenance. . . .