S.L. 123.103 Art. 2Arrangements to have effect. THE The Desiring to prevention of Have agreed This Contracting 1. This Contracting State the manner in 2. There income, or on movable or 3. The (a) in (b) in 4. The taxes which are or in place of, the shall notify each respective 1. For the (a) the rights or of natural o

It is hereby declared:

(a) that the arrangements specified in the Agreement set out in the Schedule to this Order have been made with the Republic of Singapore with a view to affording relief from double taxation in relation to the following tax imposed by the laws of Singapore: the income tax;

(b) that it is expedient that those arrangements should have effect;

(c) that the Agreement has entered into force on the 29 February, 2008. AGREEMENT BETWEEN GOVERNMENT OF THE REPUBLIC OF SINGAPORE AND THE GOVERNMENT OF MALTA FOR THE AVOIDANCE OF DOUBLE TAXATION AND THE PREVENTION OF FISCAL EVASION WITH RESPECT TO TAXES ON INCOME

Government of Malta and the Government of the Republic of Singapore, conclude an Agreement for the avoidance of double taxation and the fiscal evasion with respect to taxes on income, as follows: Article 1

PERSONAL SCOPE Agreement shall apply to persons who are residents of one or both of the States. Article 2 TAXES COVERED

Agreement shall apply to taxes on income imposed on behalf of a or of its political subdivisions or local authorities, irrespective of which they are levied. shall be regarded as taxes on income all taxes imposed on total elements of income, including taxes on gains from the alienation of immovable property. existing taxes to which the Agreement shall apply are: Malta: the income tax; (hereinafter referred to as "Malta tax"); Singapore: the income tax; (hereinafter referred to as "Singapore tax").

Agreement shall apply also to any identical or substantially similar imposed after the date of signature of the Agreement in addition to, existing taxes. The competent authorities of the Contracting States other of any significant changes which have been made in their taxation laws.

Article 3 GENERAL DEFINITIONS purposes of this Agreement, unless the context otherwise requires:

term "Malta" means the Republic of Malta and, when used in a accordance with international law, exercise sovereign jurisdiction with respect to the exploration and exploitation resources;

(b) the term "Singapore" means the territories of the Republic the territorial waters of Singapore and the sea bed and territorial waters, and when used in a geographical sense area extending beyond the limits of the territorial waters and the sea bed and sub-soil of any such area, which hereafter be designated under the laws of Singapore and with international law as an area over which Singapore rights for the purposes of exploring and exploiting the whether living or non-living;

(c) the terms "a Contracting State" and "the other Contracting Malta or Singapore as the context requires;

(d) the term "person" includes an individual, a company and of persons;

(e) the term "company" means any body corporate or any treated as a body corporate for tax purposes;

(f) the terms "enterprise of a Contracting State" and "enterprise Contracting State" mean respectively an enterprise resident of a Contracting State and an enterprise carried of the other Contracting State;

(g) the term "international traffic" means any transport by operated by an enterprise of a Contracting State, except or aircraft is operated solely between places in the other State;

(h) the term "competent authority" means:

(i) in the case of Malta, the Minister responsible for authorised representative;

(ii) in the case of Singapore, the Minister for authorised representative;

(i) the term "national" means:

(i) any individual possessing the nationality of a Contracting

(ii) any legal person, partnership or association deriving such from the laws in force in a Contracting State.