Australian Tax Treaties
This Protocol, which shall form an integral part of the Agreement, shall enter into force on the date on which the Contracting Governments exchange notes through the diplomatic channel notifying each other that the last of such things has been done as is necessary to give this Protocol the force of law in Australia and in Singapore respectively, and thereupon this Protocol shall, subject to paragraph (2), have effect:
(a) in Australia:
(i) in the case of interest to which Article 8 and paragraph (b) of Article 10 of the Protocol apply, in respect of tax on income of any year of income beginning on or after 1 July 1983; and
(ii) in any other case, in respect of tax on income of any year of income beginning on or after 1 July 1987;
(b) in Singapore:
(i) in the case of interest to which Article 8 and paragraph (b) of Article 10 of the Protocol apply, for any year of assessment beginning on or after 1 January 1984; and
(ii) in any other case, for any year of assessment beginning on or after 1 January 1988.
(2)
Where any provision of the Agreement that is affected by this Protocol would have afforded any greater relief from tax than is afforded by the amendments made by this Protocol, that provision shall continue to have effect:
(a) in Singapore, for any year of assessment beginning before the date on which this Protocol enters into force;
(b) in Australia:
(i) in the case of paragraph (2) of Article 18 of the Agreement, only in respect of dividends paid before 12 March 1988;
(ii) in respect of other income for any year of income beginning before the date on which this Protocol enters into force.
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