The WHT was challenged on the ground that the related companies concerned were subject to double taxation: wht and corporation tax suffered for the same items in their country of origin, while the French subsidiaries would not have suffered double taxation, hence the breach of the above-mentioned EU principles. On 15 January 2015, France and Singapore signed a new double taxation treaty that will enter into force in both countries after fulfilling constitutional requirements. Income received by a Member State established in a Contracting State from immovable property situated in the other Contracting State may be taxed in that other State. Income from the fixed assets of an enterprise and the income of immobile persons used for the provision of independent personal life services are also covered by this provision. Income from the direct use, rental or other use of immovable property is the subject of the contract. The term «immovable property» means immovable property within the meaning of the law of the Contracting State in which the property is located. It includes rights to variable or fixed payments in exchange for rights to variable or fixed payments in return for the exploitation of mineral and natural resources or the right to work. Although the main double taxation provisions of the original double taxation treaty have not changed, Singapore and France have significantly improved their agreement. The following taxes are covered by the double taxation convention between Singapore and France: Singapore and France signed the first double taxation convention in 1971. As economic relations between the two countries have evolved, Singapore and France have amended the treaty several times, most recently in 2015. The new double taxation agreement between Singapore and France entered into force at the beginning of 2016.
According to the governments of both countries, the 2016 agreement provides for improved general conditions for French and Singaporean companies in the other country and reduced rates for certain payments. Both countries generally apply a modified version of credit and exemption methods to eliminate double taxation. . . .