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The renewed double taxation agreement (or income tax treaty) between Taiwan and Singapore introduces numerous substantive changes for corporate groups operating in both countries. These include reductions in withholding tax rates on passive income and the elimination of several long-standing exemptions.
The mere existence of a home office does not constitute a permanent establishment in Germany. Decisive factors are the company’s actual power of disposal over the premises and the functional integration of the home office into the company’s business activities.