With reference to Articles 8 and 23. The provisions of Articles 8 and 23 of the Agreement shall apply to any item of income derived from the Federal Republic of Germany, or to any item of capital situated within the Federal Republic of Germany owned, by a company or a body of persons treated as an entity for tax purposes which is a resident of Singapore more than 50 per cent of the capital of which is owned directly or indirectly by persons who are not residents of Singapore, only if such company or body of persons proves that the Singapore tax appropriate to the income is equal to the Singapore tax which would have been appropriate to such income if the Singapore tax were computed without regard to any provision identical or similar to the provisions of section 13A of the Singapore Income Tax Act.
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