What happened
On 2 October 2026, the Philippine Department of Finance (DOF) announced that Singapore and the Philippines had concluded negotiations to modernise their 1977 Convention for the Avoidance of Double Taxation and the Prevention of Fiscal Evasion with respect to Taxes on Income. The final round took place in Singapore from 22 to 25 September 2026, about a year after the first round in early September 2025. The Philippine team was led by the DOF Revenue Operations Group and the Bureau of Internal Revenue (BIR); the Singapore team was led by IRAS's international tax division. Finance Secretary Frederick Go described the aim as modernising the framework while protecting "legitimate taxing rights". No text, rates or timetable have been released.
Why it matters
The existing treaty is nearly 50 years old and predates modern PE, anti-abuse and dispute-resolution standards. The Philippines' stated aim of protecting its taxing rights points to a negotiation over source taxation as well as relief. Services, royalties and capital gains are the likely areas of change.
A concluded negotiation is not a treaty. The usual next steps are:
- initialling and signature;
- Philippine Senate concurrence and Singapore's domestic procedures;
- entry into force;
- effect, which is typically from 1 January of a later year.
The DOF itself has said treaty updates often take several years to implement. Until then, the 1977 treaty continues to apply in full.
What to do now
Make no changes to withholding or structuring now. Inventory Singapore–Philippines dividend, interest, royalty, service and disposal flows, and note which positions rely on treaty relief, especially PE and capital gains. Watch for signature and the published text, then model the changes before the effective date.
Key resources
General information only; not tax or legal advice.
