新加坡两国的税收双边协定?
我们集团在新加坡的关联公司给上海的公司提供了附件合同ARTICLE 4所述的服务,我们想知道这样的合同是否适用于两国的税收双边协定?
ADMINISTRATIVE SUPPORT SERVICES
4.1PROVIDER hereby agrees to provide any or all administrative support Services or part thereof, as described in 4.2 hereinafter, to RECIPIENT, upon request,
The request for such Services will be made either orally or by way of written notice.
4.2The services to be provided will be the following:
a.Assistance and advice in the management of the RECIPIENT’s operations.
(See Appendix A for Details);
b.Advice and assistance in legal issues relating to tender offers, corporate and contractual matters, contractual dispute and insurance matters. Assist in contract management activities.
(See Appendix B for details);
c.Support and assistance for marketing efforts and implementation of the Group branding. Assist with communication using Group platforms and social media tools.
(See Appendix C for details);
d.Assistance in human resources for recruitment and induction programs for new hires. Coordination of operational recruiting process and staff mobility policy, coordination of training programs.
(See Appendix D for details);
e.Assistance in IT management and computer services. Coordination of operational IT policy and computer services.
(See Appendix D for details);
f.Health and Safety policies management and implementation Review of property rental agreements and negotiation for building disposal/purchase for the region.
(See Appendix D for details)
g.Finance and treasury services such as regional cash management reviews, trade documentation, project/customer risk and credit analysis and cash forecast reporting. Finance Controlling and Reporting services. Accounts payables and receivables management support and oversight, coordination with tax authorities and assist with external auditors for regional affiliates.
(See Appendix E for details)
h.Oversee Supply Chain activities including implementation of the procurement strategy set at Group level, sourcing, supplier selection, negotiation, and supplier management support in order to meet company objectives in terms of quality, cost and schedule.
(See Appendix F for details)
i.Assistance in implementing the regional business plans and Group marketing strategies set at central Group level; advice on organization and logistics. Coordination of local business plans and marketing strategies implementation.
(See Appendix G for details).
4.3 Unless the parties agree otherwise, PROVIDER will be compensated as set out in Article 5.
我们集团在新加坡的关联公司给上海的公司提供了附件合同ARTICLE 4所述的服务,我们想知道这样的合同是否适用于两国的税收双边协定?
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匿名用户
提问于 2016-04-25 11:49