On 12 May 2026, in Singapore, the Kingdom of Bhutan and the Republic of Singapore signed the Agreement for the Avoidance of Double Taxation and the Prevention of Fiscal Evasion with respect to Taxes on Income. The treaty was signed by Lekey Dorji, Finance Minister of the Royal Government of Bhutan, on behalf of Bhutan and the Gelephu Mindfulness City Special Administrative Region (GMC SAR), and by Jeffrey Siow, Acting Minister for Transport and Senior Minister of State for Finance, on behalf of the Government of the Republic of Singapore.

This briefing is intended for readers in Bhutan, in Singapore, and around the world who may have heard of double taxation treaties but who have not had the chance to study how they actually work. We explain, in everyday language, what the new Agreement does, why it matters, what it changes for taxpayers in each jurisdiction, and how an eligible taxpayer can claim its benefits. We have written it as a working guide rather than a technical commentary, and we have done our best to avoid jargon. Where legal or tax terms are unavoidable, we explain them as we go.

Nothing in this article should be treated as legal advice on any particular set of facts. The Agreement is a detailed legal instrument, and the way it applies to any specific arrangement will depend on the precise structure, residence, and source of income involved. We invite readers who are considering cross border investment or operations to consult Basnet Attorneys and Law for advice tailored to their circumstances.

1. What a Double Taxation Avoidance Agreement Is

A Double Taxation Avoidance Agreement, often abbreviated as a DTAA or simply a tax treaty, is a binding agreement between two countries that allocates the right to tax different types of cross border income. Without such an agreement, the same income can be taxed twice, once in the country where the income is earned and once again in the country where the earner lives or is established. The result is that profits, salaries, dividends, interest, and royalties can be eroded by overlapping tax burdens that discourage trade and investment.

A DTAA solves this problem in three ways. First, it sets out clear rules for deciding which of the two countries has the primary right to tax a given category of income. Second, it caps the rate of tax that the source country can impose on certain payments, such as dividends, interest, and royalties, that flow across the border. Third, it requires the country of residence either to exempt the income that has already been taxed at source or to give a credit for the foreign tax paid, so that the taxpayer is not taxed twice on the same income.

In addition to relieving double taxation, modern DTAAs serve a second purpose that has become equally important. They give the tax authorities of each country a framework for cooperation. They allow the two revenue services to exchange information, to resolve disputes through a mutual agreement procedure, and to prevent abuse by persons who would otherwise try to use the treaty to shelter income that should properly be taxed. The Bhutan and Singapore DTAA reflects all of these features and is aligned with current international standards developed under the OECD and United Nations model conventions, as updated by the BEPS framework.

2. Background to the Bhutan and Singapore Agreement

The Agreement is the third bilateral tax treaty negotiated by the Royal Government of Bhutan. It was negotiated with the active participation of representatives of the Gelephu Mindfulness City Authority, the institutional body responsible for the GMC Special Administrative Region. This participation reflects the unique constitutional and economic position of GMC SAR as a designated zone within Bhutan that has been mandated to attract international investment, financial services, and professional talent.

At the signing, Dasho (Dr.) Lotay Tshering, Governor of GMC, described the Agreement as an important milestone for the Special Administrative Region. He noted that the treaty reflects the growing relationship between GMC and Singapore and represents formal recognition by Singapore of GMC and its vision. Recognition of this kind by jurisdictions such as Singapore, he observed, is a strong indication that GMC is on a credible path towards becoming an economic hub for South Asia.

Finance Minister Lekey Dorji, welcoming the signing, expressed appreciation for Singapore’s trust and cooperation. He observed that Singapore, although small in geographic terms, carries economic weight and credibility well beyond its size, and is therefore an especially important partner for Bhutan. He added that the Agreement supports both the Royal vision for Gelephu Mindfulness City and the Royal Government’s broader ambition for Bhutan’s long term economic development.

For Singapore, the Agreement adds Bhutan to its extensive network of more than ninety comprehensive tax treaties. For Bhutan, it deepens the legal and fiscal foundations that international investors expect before committing capital. For GMC SAR, it is part of the institutional architecture that the new city is putting in place to welcome high quality international investors, financial institutions, family offices, fund managers, and professional service firms.

3. Scope and Coverage of the Agreement

The Agreement applies to persons who are residents of one or both of the contracting states. A person, in this context, includes individuals, companies, partnerships, and other bodies of persons that are treated as taxable entities under the domestic law of either Bhutan or Singapore. Residence for treaty purposes is determined first under domestic law and, in cases of overlap, by a sequence of tie breaker rules set out in the Agreement.

The taxes covered by the Agreement are taxes on income imposed by each country. On the Bhutan side, this includes the Bhutan income taxes administered by the Department of Revenue and Customs and, where applicable, the income tax framework that governs activities within Gelephu Mindfulness City SAR. On the Singapore side, this includes the Singapore income tax administered under the Income Tax Act 1947. The Agreement also covers any identical or substantially similar taxes that either country may introduce after the Agreement enters into force, so that the treaty continues to function even as tax legislation evolves.

The Agreement is, in principle, comprehensive. It addresses business profits, income from immovable property, dividends, interest, royalties, capital gains, income from employment, directors’ fees, income of artistes and sportspersons, pensions, government service, students and trainees, and other income not otherwise covered. It also includes the standard accompanying articles on residence, permanent establishment, associated enterprises, methods for elimination of double taxation, non-discrimination, mutual agreement procedure, exchange of information, members of diplomatic missions, entry into force, and termination.

4. Key Concepts the Reader Should Know

4.1 Residence

Residence is the gateway concept in any tax treaty. A taxpayer must be a resident of Bhutan or Singapore, as the case may be, in order to claim the benefits of the Agreement. Residence is determined under domestic law, but where a person qualifies as a resident of both countries, the Agreement provides tie breaker rules. For individuals, these rules look in turn at the permanent home, the centre of vital interests, the habitual abode, and finally the nationality of the person. For companies and other entities, the place of effective management is generally the deciding factor, with disagreements resolved by mutual agreement between the competent authorities.

4.2 Permanent Establishment

A permanent establishment, or PE, is a fixed place of business through which the business of an enterprise is wholly or partly carried on. Examples include a branch, an office, a factory, a workshop, a mine, an oil or gas well, or a building site or installation project that lasts more than the period specified in the Agreement. The concept matters because it determines when a business of one country becomes taxable on its business profits in the other country. If a Singapore company carries on business in Bhutan without a PE, its business profits are generally taxable only in Singapore. If it has a PE in Bhutan, Bhutan may tax the profits attributable to that PE. The reverse applies to a Bhutanese enterprise operating in Singapore.

4.3 Source and Residence

Two principles run through every article of the Agreement. The source principle says that the country in which income arises has a right to tax it. The residence principle says that the country in which the taxpayer is resident also has a right to tax it. The Agreement reconciles the two by allocating exclusive taxing rights in some cases and shared taxing rights in others, and by requiring the residence country to grant relief from double taxation where the source country has been allowed to tax.

5. Key Substantive Provisions

5.1 Business Profits

Under the Agreement, the business profits of an enterprise of Bhutan are taxable only in Bhutan unless that enterprise carries on business in Singapore through a permanent establishment situated there. In that case, only the profits attributable to the permanent establishment may be taxed in Singapore. The same rule applies in reverse to a Singapore enterprise operating in Bhutan or in GMC SAR. The attribution of profits is to be made as if the permanent establishment were a separate and independent enterprise dealing at arm’s length with the rest of the company.

5.2 Income from Immovable Property

Income derived from immovable property, including income from agriculture or forestry, is taxable in the country where the property is situated. A Singapore resident who owns land or buildings in Bhutan will therefore be taxable in Bhutan on the rental income from that property, and a Bhutanese resident who owns property in Singapore will be taxable in Singapore on the rental income from that property. The country of residence will normally provide relief from double taxation by way of credit.

5.3 Dividends, Interest, and Royalties

Dividends paid by a company that is a resident of one country to a resident of the other country may be taxed in the country of residence of the recipient. They may also be taxed in the country of the paying company, but the Agreement caps that source country tax at the rates negotiated between the two governments. The same approach applies to interest and royalties, each of which has its own withholding tax cap and definition. Reduced rates of this kind are one of the most commercially significant features of any DTAA, because they directly affect the net return on cross border investments such as shareholdings, loans, and licensing arrangements.

To obtain these reduced rates, the recipient must be the beneficial owner of the income. This means that the recipient must have real economic ownership of the income and not be a mere conduit holding the income on behalf of a third person who would not be entitled to the same treaty benefits. The beneficial ownership requirement is one of the principal anti-abuse safeguards built into the Agreement.

5.4 Capital Gains

Gains derived from the alienation of immovable property are taxable in the country where the property is situated. Gains from the alienation of movable property forming part of a permanent establishment are taxable in the country where the PE is situated. Gains from the alienation of shares deriving their value principally from immovable property are, in line with current treaty practice, taxable in the country where that immovable property is located. Other gains are generally taxable only in the country of residence of the alienator, subject to the specific allocation rules set out in the Agreement.

5.5 Employment Income, Directors’ Fees, Artistes and Sportspersons

Salaries, wages, and similar remuneration derived by a resident of one country in respect of employment are taxable only in that country unless the employment is exercised in the other country. Even where the work is performed in the other country, a short-stay exemption applies if the employee is present for not more than the period specified in the Agreement and certain conditions on the employer and on the cost-bearing entity are met. Directors’ fees may be taxed in the country where the company paying the fees is resident. Income earned by artistes and sportspersons in respect of personal activities performed in the other country may be taxed in that other country, subject to limited exceptions for activities supported by public funds.

5.6 Pensions and Government Service

Pensions and other similar remuneration paid in consideration of past private employment are, as a general rule, taxable only in the country of residence of the recipient. Payments made under the social security system of a country, and remuneration paid by a government of one country to its own nationals for services rendered to that government, are normally taxable only in the paying country. These rules allow retired persons and government employees to know in advance which country will tax their pension or salary.

5.7 Other Income

Items of income that are not specifically covered by any other article of the Agreement are taxable only in the country of residence of the recipient, again subject to the safeguards built into the treaty against artificial structuring. This residual category ensures that no item of income falls outside the framework that the Agreement creates.

6. How the Agreement Eliminates Double Taxation

The mere allocation of taxing rights is not enough to eliminate double taxation. The Agreement therefore contains a specific article setting out the method by which each country relieves the double taxation that may otherwise arise. The two principal methods used in international treaty practice are the exemption method and the credit method.

Under the exemption method, the country of residence exempts from its own tax the income that may be taxed in the source country. Under the credit method, the country of residence taxes the foreign income in the ordinary way but allows the taxpayer to deduct, from its domestic tax on that income, the tax already paid in the source country. The deduction is capped at the amount of domestic tax otherwise payable on the foreign income, so that the credit cannot exceed the tax that would have been due at home on that same income.

The Bhutan and Singapore Agreement combines these methods in the way that is now standard among modern treaty networks, with each country undertaking to grant relief by credit or exemption, as the case may be, for tax paid in accordance with the Agreement in the other country.

Taxpayers should expect that, in the great majority of cases, the credit method will apply, and that careful documentation of foreign tax paid will be necessary in order to obtain relief.

7. Cooperation, Anti-Abuse, and Dispute Resolution

7.1 Exchange of Information

The Agreement provides for the exchange of information between the competent authorities of Bhutan and Singapore to the extent foreseeably relevant for carrying out the provisions of the Agreement or the administration and enforcement of the domestic tax laws of the two countries. Information received is to be treated as confidential in the same manner as information obtained under domestic law, and is to be disclosed only to persons and authorities concerned with the assessment, collection, enforcement, prosecution, or determination of appeals in relation to the taxes covered. The Agreement reflects current international standards on transparency and exchange of information in tax matters.

7.2 Prevention of Treaty Abuse

Consistent with current best practice, the Agreement includes safeguards against the abuse of its provisions. These include the beneficial ownership requirement in the articles on dividends, interest, and royalties, and a general anti-abuse rule. The general rule provides that a benefit under the Agreement shall not be granted in respect of an item of income if it is reasonable to conclude, having regard to all relevant facts and circumstances, that obtaining that benefit was one of the principal purposes of any arrangement or transaction, unless it is established that granting the benefit in those circumstances is consistent with the object and purpose of the relevant provisions. This is the so called principal purposes test, now common in modern DTAAs.

7.3 Mutual Agreement Procedure

Where a taxpayer considers that the actions of one or both of the contracting states result, or will result, in taxation not in accordance with the Agreement, the taxpayer may present the case to the competent authority of the country in which it is resident. The competent authorities are then required to endeavour to resolve the case by mutual agreement, irrespective of the time limits in domestic law. This procedure provides an essential safety valve where the application of the Agreement is unclear or contested in practice, and it is an important reason why taxpayers and their advisers should take care to document positions taken under the treaty at the time they are taken.

7.4 Non-Discrimination

The Agreement contains a non-discrimination article that prevents either country from imposing on nationals or enterprises of the other country a tax burden that is heavier than that imposed on its own nationals or enterprises in the same circumstances. The article protects the equal treatment of taxpayers and is itself enforceable through the mutual agreement procedure.

8. What the Agreement Means for Bhutan

For Bhutan, the Agreement is a significant step in the deliberate, careful expansion of the country’s international economic engagement. It supplies a piece of legal infrastructure that international investors expect to see before they will commit serious capital. Without a treaty, a Singapore investor placing money into a Bhutanese company would have to deal with the risk that dividends, interest, or royalties flowing back to Singapore could be taxed both at source in Bhutan and again in Singapore. The Agreement removes that risk by capping source country tax at agreed rates and by obliging Singapore to grant relief for the Bhutanese tax suffered.

For Bhutanese enterprises and entrepreneurs, the Agreement is just as useful in the opposite direction. A Bhutanese company that wishes to set up a regional office, a financial subsidiary, or a service hub in Singapore now has clear rules on when its presence in Singapore will give rise to a permanent establishment, when Singapore will be entitled to tax the resulting profits, and how Bhutan will give credit for any Singapore tax paid. The transparency that the Agreement provides reduces the cost of doing business in Singapore for Bhutanese parties.

For the Royal Government of Bhutan and its tax administration, the Agreement strengthens the toolkit available to combat fiscal evasion. The exchange of information article allows the Department of Revenue and Customs to seek information from the Inland Revenue Authority of Singapore where there is reason to believe that Bhutanese tax residents are using cross border structures to conceal income. The anti-abuse provisions ensure that the treaty itself cannot be used to shelter income from tax that would otherwise be properly payable in Bhutan.

At a strategic level, the Agreement signals that Bhutan is serious about integrating with the global economy on terms that protect its fiscal sovereignty. It complements the country’s broader efforts to modernise its investment, company, and tax laws, and it strengthens the foundations on which Bhutan can negotiate further treaties in the years ahead.

9. What the Agreement Means for Singapore

For Singapore, the Agreement adds a new partner to one of the most extensive comprehensive tax treaty networks in the world. Singapore has long pursued a treaty strategy designed to support its position as a regional headquarters location, a financial centre, and a base for international holding, financing, and trading activities. Each new treaty extends the reach of that platform.

For Singapore investors, the Agreement reduces the cost of placing capital into Bhutan and into Gelephu Mindfulness City SAR. A Singapore parent company can now plan its investments into Bhutan with greater confidence about the tax burden that will arise on profits, dividends, interest, and royalties. Singapore based fund managers, family offices, and professional advisers acquire a new lawful and transparent route through which their clients can deploy capital into a frontier market with strong long term growth prospects.

For Singapore as a jurisdiction, the Agreement is also part of its continued positioning as a responsible international financial centre. By concluding a treaty that incorporates the principal purposes test, the beneficial ownership requirement, and a robust exchange of information article, Singapore reinforces its alignment with the standards developed under the OECD and the Global Forum on Transparency and Exchange of Information.

Finally, the Agreement deepens Singapore’s diplomatic and economic ties with the Kingdom of Bhutan at a moment when Bhutan has launched one of the most ambitious development projects in the region. The treaty places Singapore on the ground floor of that project, both as an investor and as a trusted partner.

10. What the Agreement Means for Gelephu Mindfulness City

Gelephu Mindfulness City Special Administrative Region is a flagship initiative of the Kingdom of Bhutan, conceived as a forward looking economic and spiritual hub on the southern border of the country. The vision for GMC SAR is to attract long term, high quality international investment in fields such as sustainable finance, technology, education, healthcare, hospitality, and professional services, while preserving the cultural and environmental values that define Bhutan.

The Agreement supports this vision in several concrete ways. It is the first comprehensive tax treaty concluded since the establishment of the GMC SAR framework that expressly contemplates the participation of the GMC Authority in the negotiation process. Investors looking at GMC SAR now have a clear treaty based answer to the most basic questions any international investor will ask, which are how their profits will be taxed, whether their dividends and interest can flow home efficiently, and whether the host jurisdiction is recognised by reputable international partners.

Equally important is the reputational signal that the Agreement sends. The signing of a comprehensive DTAA with Singapore, a jurisdiction widely regarded as a benchmark of credibility and good governance in Asia, is a formal endorsement of GMC SAR as a serious counterparty. As Governor Dasho (Dr.) Lotay Tshering observed at the signing, recognition of this kind is a strong sign of the progress that GMC is making in becoming an economic hub for South Asia.

For financial institutions, family offices, and professional service providers considering a presence in GMC SAR, the Agreement reduces friction. Cross border secondments of employees, intra group financing flows, licensing of intellectual property, and the structuring of investment funds can all now be analysed against a clear treaty framework. The Agreement does not, of course, replace the need for sound legal, tax, and regulatory advice on the structure of any particular project, but it removes a significant layer of uncertainty.

11. How to Claim Benefits Under the DTAA

Claiming the benefits of a DTAA is a procedural exercise that has to be done carefully and on time. The treaty does not apply automatically. A taxpayer must establish entitlement, satisfy any documentary requirements imposed by the source country, and file the relief claim in the form and within the deadlines required. The following outline describes the typical sequence. Specific procedures will vary depending on the type of income, the country involved, and the position of the taxpayer.

Step 1: Confirm Residence

The taxpayer should first confirm that it qualifies as a resident of Bhutan or of Singapore, as the case may be, under the residence article of the Agreement. In practice this is done by obtaining a Tax Residency Certificate, often abbreviated as TRC, from the tax authority of the country of residence. In Singapore, the TRC is issued by the Inland Revenue Authority of Singapore on application by the taxpayer. In Bhutan, the equivalent certificate is issued by the Department of Revenue and Customs, with corresponding procedures applicable for taxpayers operating within GMC SAR.

Step 2: Identify the Article That Applies

The taxpayer should then determine which article of the Agreement applies to the income in question. Dividends, interest, royalties, business profits, employment income, capital gains, and pensions each have their own article. The classification matters because the rate of relief and the documentary requirements depend on the article that applies.

Step 3: Satisfy the Beneficial Ownership and Anti-Abuse Tests

Where the article in question requires the recipient to be the beneficial owner of the income, the taxpayer should be able to demonstrate that it has the real economic ownership of the income and that it is not acting as a conduit. The taxpayer should also be in a position to show that the principal purposes test is not engaged by the arrangement, which generally means being able to evidence the genuine commercial reasons for the structure used.

Step 4: Submit the Claim to the Source Country

The taxpayer, or the payer of the income acting on its behalf, then submits the claim to the source country tax authority. In a typical case, this involves filing a treaty claim form together with a TRC, a self declaration of beneficial ownership, and any supporting documentation that the source country requires. For payments such as dividends, interest, and royalties, the payer often applies the reduced treaty rate at source on the strength of the documentation provided, subject to subsequent audit. For business profits and other items, the claim is generally made through the annual tax return.

Step 5: Claim Foreign Tax Credit in the Country of Residence

Once the source country tax has been paid, the taxpayer claims a foreign tax credit, or in some cases an exemption, in the country of residence by reference to the credit or exemption method article. This is normally done through the annual tax return in the country of residence. The taxpayer should retain copies of the source country tax certificates, payment evidence, and any correspondence with the source country tax authority.

Step 6: Use the Mutual Agreement Procedure if Necessary

If, despite the proper application of the Agreement, the taxpayer is still being taxed in a manner that does not appear to be consistent with the treaty, the taxpayer may invoke the mutual agreement procedure. The case is presented to the competent authority of the country of residence, which then engages with its counterpart in the other country to seek a resolution. Time limits and procedural details apply, and professional advice is strongly recommended before invoking this procedure.

Throughout the process, careful documentation is the single most important factor in securing the benefits of the Agreement. Tax residency certificates, beneficial ownership declarations, board minutes, agreements, invoices, and evidence of foreign tax paid should all be assembled and retained. Where the structure is complex, or where the amounts involved are significant, it is prudent to obtain advance written advice on entitlement to treaty benefits before the income arises.

12. Practical Considerations for Businesses and Investors

Investors, family offices, and businesses considering cross border activity between Bhutan and Singapore, or with Gelephu Mindfulness City SAR, should take the time to plan how they will use the Agreement. There are several practical considerations that arise in almost every case.

• Structure the investment with substance in the country claiming treaty benefits. The beneficial ownership requirement and the principal purposes test mean that thin or artificial structures are unlikely to obtain the benefit of the Agreement. Real offices, real people, real decision making, and real economic activity matter.

• Document residence and beneficial ownership before the income arises. Obtaining a Tax Residency Certificate and preparing a beneficial ownership declaration in advance is far easier than reconstructing the position after a withholding tax has already been deducted at the full domestic rate.

• Map the cash flows and tax cost of the structure. Each type of payment, including dividends, interest, royalties, services, and management fees, may attract a different rate of withholding tax. A careful map of the flows allows the parties to identify and resolve issues at the design stage.

• Watch the permanent establishment threshold. Sending employees on extended secondments, providing services through agents, or running long construction or installation projects in the other country can give rise to a permanent establishment. The PE article should be reviewed at the planning stage of any project.

• Coordinate with domestic law. The Agreement allocates taxing rights and provides relief, but the underlying liability, the rates, and the procedural rules continue to be governed by the domestic law of each country. Domestic incentives, exemptions, and concessions, including those that may apply within GMC SAR, should be analysed alongside the treaty.

• Maintain a treaty file. For each cross border income stream, a dedicated treaty file containing the TRC, beneficial ownership declarations, calculations of relief, and copies of the relevant treaty claim forms is invaluable in case of audit.

13. Entry into Force and Effective Date

The Agreement will enter into force in accordance with its own provisions, after each country has completed the internal procedures required to ratify it and the two governments have exchanged the necessary instruments or notifications. Once in force, the Agreement will have effect from the dates specified in its final articles. These dates are typically expressed by reference to the year of assessment or the calendar year following entry into force, and they may be different for withholding taxes and for other taxes.

Taxpayers should not assume that the Agreement is already operational simply because it has been signed. Until it formally enters into force and reaches its effective date, the existing position under domestic law continues to apply. We will issue further briefings as the ratification timetable becomes clearer, and we will update our clients on the precise dates from which relief under the Agreement can be claimed.

14. Conclusion

The Bhutan and Singapore Double Taxation Avoidance Agreement is more than a technical instrument. It is a measured, deliberate step in the modernisation of Bhutan’s international economic relationships, and it is a building block for the long term success of Gelephu Mindfulness City SAR. It places the relationship between Bhutan and Singapore on a more certain legal footing, it lowers the tax friction for legitimate cross border activity, and it strengthens the cooperation between the two tax administrations against evasion and abuse.

For investors, businesses, and professionals on both sides, the Agreement creates opportunities that did not exist before, but it also raises new questions about structuring, documentation, and compliance. The taxpayers who will benefit the most are those who understand the Agreement, who plan their affairs with it in mind, and who put in place the documentation that allows them to claim its benefits cleanly and on time.

Basnet Attorneys and Law is honoured to support clients in Bhutan, in Singapore, and in third jurisdictions to make the most of the new framework. Our team advises on residence and permanent establishment, on the design and documentation of cross border investments, on treaty based withholding tax planning, on the preparation of foreign tax credit claims, and on the conduct of mutual agreement procedures. We welcome enquiries from any reader who wishes to understand how the Agreement applies to a particular situation.

About Basnet Attorneys and Law

Basnet Attorneys and Law is a full service law firm with a particular focus on corporate law, international tax, cross border investment, corporate and commercial law, and the legal infrastructure of Gelephu Mindfulness City Special Administrative Region. The firm advises corporations, financial institutions, family offices, and individuals on the legal and tax questions that arise from doing business across the borders of Bhutan, GMC SAR,  and the wider region.

For further information on the Bhutan and Singapore DTAA, or for tailored advice on a specific matter, please contact us by writing to [email protected].

Disclaimer

This article has been prepared by Basnet Attorneys and Law for general information only. It does not constitute legal, tax, or other professional advice. The Bhutan and Singapore Double Taxation Avoidance Agreement is a detailed legal instrument and its application to any particular set of facts will depend on the specific circumstances. Readers should obtain specific professional advice before taking, or refraining from, any action on the basis of the information contained in this article. No liability is accepted by the firm or by any author of this article for any loss occasioned to any person acting or refraining from acting in reliance on its contents.