The agreement and its history

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The Agreement between the Republic of Singapore and the Swiss Confederation for the Avoidance of Double Taxation with respect to Taxes on Income was signed in Singapore on 24 February 2011. It entered into force on 1 August 2012 and took effect for Singapore from 1 January 2013. It replaced a 1975 agreement that predated both countries' modern financial centres and had no effective exchange of information clause.¹ A protocol signed on 27 July 2017 brought the agreement into line with the BEPS minimum standards on treaty abuse and dispute resolution, because Switzerland chose to implement those standards bilaterally with most partners instead of through the Multilateral Instrument. The agreement is therefore not modified by the MLI and must be read with its 2017 protocol.²

The agreement covers income taxes only. Switzerland's wealth tax and the cantonal inheritance and gift taxes are outside it, as is Singapore's GST and stamp duty. That scope is the first thing a client with assets in both places must grasp. The Swiss wealth tax on tokens held by a Swiss resident is unaffected by anything in the treaty. A Singapore resident with Swiss tokens pays no Swiss wealth tax because he is not Swiss-resident, treaty or no treaty. The treaty allocates taxing rights over income between the two states according to the OECD model of its time and sets out in Article 4 the rules that decide, when both states claim a person as resident, which of them wins.

Notes

Agreement between the Republic of Singapore and the Swiss Confederation for the Avoidance of Double Taxation with respect to Taxes on Income, signed 24 February 2011, in force 1 August 2012; SR 0.672.968.91; IRAS, list of DTAs, Switzerland. ↩
Protocol amending the Agreement of 24 February 2011, signed 27 July 2017. ↩

For general information only. This article does not constitute legal or tax advice, does not replace advice on an individual case and creates no lawyer-client relationship. It reflects the legal position as of October 2026.

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Dr Alexander Ressos, TEP

Of Counsel, KGP Legal LLC

I am Of Counsel with KGP Legal LLC in Singapore, where I work with a global client base of successful entrepreneurs and their families, independent asset managers, commodity trading houses and other commercial clients. I am a German and Swiss attorney-at-law, also admitted as a solicitor in England & Wales and in Hong Kong. I divide my time between Zug in Switzerland, Singapore and Hong Kong. Since 2017 I have advised international clients on more than 700 crypto and digital asset projects. I also have extensive experience in cross-border litigation and arbitration in Singapore, Hong Kong and other markets in South-East Asia and Greater China.

I operate across the key financial centres in South-East Asia, the Middle East and Switzerland, with a particular focus on asset protection, international tax and estate planning, as well as trusts, company administration and other fiduciary services. My philosophy is to serve as a trusted advisor working closely with my clients and to help them achieve their commercial objectives.

All Singapore law advice is provided through KGP Legal LLC, an established and duly licensed firm of Singapore advocates and solicitors.

KGP Legal LLC is a medium-sized law firm in Singapore that is capable of providing the full range of legal services and corporate administration work. Please contact me directly at [email protected] if you need any further information.

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SingaporeIQ is edited by Dr Alexander Ressos, an international business lawyer with more than 15 years of local experience in Singapore as a permanent resident, a Singapore registered foreign lawyer and managing partner of a Singapore foreign law practice. In addition to significant experience in cross-border investments and transactions, UHNWI private client work and sanctions/export controls, Dr Ressos has extensive experience in cross-border business and in crypto and digital-asset projects in Singapore, drawn from more than 700 projects since 2017.

If you are planning a company incorporation, an investment, a holding structure or a market entry through Singapore, you can reach Dr Ressos directly at [email protected]. Singapore law advice is provided by KGP Legal LLC, a licensed firm of Singapore advocates and solicitors. As a Singapore law practice, KGP Legal LLC is authorised under the Legal Profession Act 1966 to advise on Singapore law and to represent clients before the Singapore courts; foreign law practices with an office in Singapore are, as a rule, not permitted to do either. Dr Ressos and his team facilitate the full range of Singapore legal, compliance and company administration services, including company incorporation, corporate transactions, commercial contracts, crypto and digital assets, financial regulatory work and dispute resolution, including litigation in the Singapore courts. For legal, tax and fiduciary services in Switzerland, see helveticaregister.com.