Common use of Sources of Income Clause in Contracts

Sources of Income. 1. For the purposes of this Agreement - (i) dividends paid by a company which is resident in Singapore for the purposes of Singapore tax to a New Zealand resident shall be treated as income from sources in Singapore; (ii) dividends paid by a Malaysian company out of profits derived from sources in Singapore to a New Zealand resident shall be treated as income from sources in Singapore; (b) dividends paid by a company which is resident in New Zealand for the purposes of New Zealand tax to a Singapore resident shall be treated as income from sources in New Zealand; (c) profits derived by a resident of a Contracting State from the operation of ships or aircraft, being profits from operations confined solely to places in the other Contracting State, shall be treated as having a source in that other Contracting State; (d) interest shall be treated as having a source in a Contracting State where the person paying the interest is the Government of that Contracting State or a resident of that Contracting State. Where, however, the person paying the interest, whether he is a resident of a Contracting State or not, has in a Contracting State a permanent establishment and the interest is borne by such permanent establishment, then such interest shall be treated as having a source in the Contracting State in which the permanent establishment is situated; (e) royalties (as defined in Article 10) and payments referred to in subparagraph (j)(ii), subparagraph (j)(iii) or subparagraph (j)(iv) of paragraph 1 of Article 2 shall be treated as having a source in a Contracting State where the person paying such royalties or making such payments is the Government of that Contracting State or a resident of that Contracting State. Where, however, the person paying such royalties or making such payments, whether he is a resident of a Contracting State or not, has in a Contracting State a permanent establishment and such royalties or payments are borne by such permanent establishment, then such royalties or payments shall be treated as having a source in the Contracting State in which the permanent establishment is situated; (f) natural resource royalties and income referred to in subparagraph (j)(v), subparagraph (j)(vi) or subparagraph (j)(vii) of paragraph 1 of Article 2 derived by a resident of a Contracting State shall be treated as derived from sources in the other Contracting State if the land, mine, quarry, natural resource, standing timber or rent-producing property is situated in that other Contracting State. 2. Notwithstanding anything contained in Article 16 where income of any of the kinds referred to in paragraph 1 of this Article is derived by a resident of a Contracting State and is not, under the provisions of that paragraph, treated as having a source in the other Contracting State, such income shall be exempt from tax in that other Contracting State.

Sources of Income. 1. For the purposes of this Agreement -Agreement-- (ia) dividends paid by a company which is resident in Singapore Malaysia for the purposes of Singapore Malaysian tax to a New Zealand resident shall be treated as income from sources in Singapore; (ii) dividends paid by a Malaysian company out of profits derived from sources in Singapore to a New Zealand resident shall be treated as income from sources in SingaporeMalaysia; (b) dividends paid by a company which is resident in New Zealand for the purposes of New Zealand tax to a Singapore Malaysian resident shall be treated as income from sources in New Zealand; (c) remuneration in respect of employment exercised aboard a ship or aircraft operated in international traffic by a resident of a Contracting State shall be treated as having a source in that Contracting State; (d) income or profits derived by a resident of a Contracting State from the operation of ships or aircraft, being income or profits from operations confined solely to places in the other Contracting State, shall be treated as having a source in that other Contracting State; (de) interest shall be treated as having a source in a Contracting State where the person paying the interest is the Government of that Contracting State or a resident of that Contracting State. Where, however, the person paying the interest, whether he is a resident of a Contracting State or not, has in a Contracting State a permanent establishment and the interest is borne by such permanent establishment, then such interest shall be treated as having a source in the Contracting State in which the permanent establishment is situated; (ef) royalties (as defined in paragraph 3 of Article 10) and payments referred to in subparagraph (j)(ii), subparagraph (j)(iii) or subparagraph (j)(iv) of paragraph 1 of Article 2 shall be treated as having a source in a Contracting State where the person paying such royalties or making such payments is the Government of that Contracting State or a resident of that Contracting State. Where, however, the person paying such royalties or making such paymentsroyalties, whether he is a resident of a Contracting State or not, has in a Contracting State a permanent establishment and such royalties or payments are borne by such permanent establishment, then such royalties or payments shall be treated as having a source in the Contracting State in which the permanent establishment is situated; (fg) natural resource royalties and income or profits referred to in subparagraph (j)(vk) (ii), subparagraph (j)(vik) (iii) or subparagraph (j)(viik) (iv) of paragraph 1 of Article 2 derived by a resident of a Contracting State shall be treated as derived from sources in the other a Contracting State if the land, mine, quarry, natural resource, standing timber or rent-producing property is situated in that other Contracting State. 2. Notwithstanding anything contained in Article 16 17 where income or profits of any of the kinds referred to in paragraph 1 of this Article is derived by a resident of a Contracting State and is not, under the provisions of that paragraph, treated as having a source in the other Contracting State, such income or profits shall be exempt from tax in that other Contracting State.