Section 13

subject to subsection (2) and such conditions as may be prescribed by regulations, the interest derived from —

any qualifying debt securities issued during the period from 28 February 1998 to 31 December 2023 (both dates inclusive) by any person who is not resident in Singapore and who does not have any permanent establishment in Singapore; and

any qualifying debt securities issued during the period from 27 February 1999 to 31 December 2023 (both dates inclusive) by any person who is not resident in Singapore and who carries on any operation in Singapore through a permanent establishment in Singapore where the funds used by that person to acquire the qualifying debt securities are not obtained from the operation;

any person who is not resident in Singapore and who does not have any permanent establishment in Singapore; or

any person who is not resident in Singapore and who carries on any operation in Singapore through a permanent establishment in Singapore where the funds used by that person to acquire the qualifying debt securities are not obtained from the operation;

who is not resident in Singapore and who does not have any permanent establishment in Singapore; and

who is not resident in Singapore and who carries on any operation in Singapore through a permanent establishment in Singapore where the funds used by that person to acquire the qualifying debt securities are not obtained from the operation;

subject to subsections (2C) and (2D) and such conditions as may be prescribed by regulations —

the interest derived by any person from any qualifying project debt securities issued during the period from 1 November 2006 to 31 December 2022 (both dates inclusive);

the discount, prepayment fee, redemption premium and break cost derived by any person from any qualifying project debt securities issued during the period from 15 February 2007 to 31 December 2022 (both dates inclusive); and

such other income derived by any person that is directly attributable to qualifying project debt securities issued on or after a prescribed date, as may be prescribed by regulations;

who is not resident in Singapore and who does not have any permanent establishment in Singapore; and

who is not resident in Singapore and who carries on any operation in Singapore through a permanent establishment in Singapore where the funds used by that person to acquire the qualifying debt securities are not obtained from the operation;

who is not resident in Singapore and who does not have any permanent establishment in Singapore; and

who is not resident in Singapore and who carries on any operation in Singapore through a permanent establishment in Singapore where the funds used by that person to acquire the qualifying debt securities are not obtained from the operation;

the interest, discount, prepayment fee, redemption premium and break cost derived by any person from any qualifying debt securities (excluding Singapore Government Securities) which —

are issued during the period from 16 February 2008 to 31 December 2018 (both dates inclusive);

have an original maturity of not less than 10 years;

either —

cannot be re‑opened with a resulting tenure of less than 10 years to the original maturity date; and

such other income, as may be prescribed by regulations, derived by any person that is directly attributable to qualifying debt securities (excluding Singapore Government Securities) which —

are issued on or after such date as may be prescribed by regulations;

have an original maturity of not less than 10 years;

cannot have their tenure shortened to less than 10 years from the date of their issue, except under such circumstances as may be prescribed by regulations; and

cannot be re‑opened with a resulting tenure of less than 10 years to the original maturity date;

which are qualifying debt securities and issued during the period from 16 February 2008 to 31 December 2018 (both dates inclusive); and

the amount payable from which is not deductible against any income of the issuer of those securities accruing in or derived from Singapore;

the official emoluments payable from Commonwealth funds to members of Commonwealth forces, and to persons in the service of a Commonwealth government, in Singapore, in respect of their offices under such Commonwealth government, if such emoluments are subject to income tax in such Commonwealth country;

any gains or profits arising from sums standing in the SRS account of any SRS member except where section 10G(13) applies;

the income of any institution, authority, person or fund specified in the First Schedule;

the income of —

any bona fide friendly society approved by the Comptroller;

any co‑operative society registered under the Co‑operative Societies Act 1979;

[Deleted by Act 29 of 2012](h)any sum received by way of commutation of pensions granted under any written law relating to pensions in Singapore or, in the case of any other pension scheme, any sum received by way of commutation of pensions by an individual under such a scheme to the extent of such sum as the Comptroller may determine relating to the period of employment of that individual with the employer before 1 January 1993;

sums received by way of death gratuities or as consolidated compensation for death or injuries;

sums standing to the account of an individual in the Central Provident Fund or any approved pension or provident fund designated by the Minister under section 39(8) or withdrawn therefrom;

$1,500 per year (for contributions made before 2018); or

$2,730 per year (for contributions made in 2018 and in each subsequent year),less any previous contribution that is made to the same medisave account in the same year by the person of the prescribed description in the person’s capacity as an employer (if applicable), and that is not treated as income under section 10B(5A);

sums derived from, or received in, Singapore as pensions, being —

wound or disability pensions granted to members or former members of a Commonwealth force;

pensions granted to dependent relatives of any such member killed on war service or who died as a result of war service injuries; or

wound or disability pensions granted to members or former members of civil defence organisations;

pensions granted to any person under the provisions of the Widows’ and Orphans’ Pension Act 1904 or under any approved scheme within the meaning of that Act and pensions paid, by or out of any approved pension or provident fund or society, to or for the benefit of the widow or children of a deceased contributor to such fund or society;

the income of any trade union registered under the Trade Unions Act 1940 insofar as such income is not derived from a trade or business carried on by such trade union;

any income derived in the basis period for any year of assessment before the year of assessment 2018 by any person who is not resident in Singapore from trading in Singapore through consignees in any of the following commodities produced outside Singapore:

rubber;

copra;

pepper;

tin;

tin‑ore;

gambia;

sago flour;

cloves;

[Deleted by Act 32 of 2019](oa)payments liable to be made on or after 17 February 2012 to a person not resident in Singapore (excluding any permanent establishment in Singapore) for the charter of any ship (as defined in section 2(1) of the Merchant Shipping Act 1995) under any agreement or arrangement;

[Deleted by Act 34 of 2016](q)the investment income of any approved pension or provident fund or society;

the income derived during the period from 3 May 2002 to 31 March 2022 (both dates inclusive) by an individual not resident in Singapore from acting as an arbitrator, and for this purpose, “arbitrator” means an individual appointed for any arbitration which is governed by the Arbitration Act 2001 or the International Arbitration Act 1994 or would have been governed by either of those Acts had the place of arbitration been Singapore;

that takes place in Singapore; or

that would have taken place in Singapore but for the settlement of the dispute or withdrawal of the claim in question;

that takes place in Singapore; or

that would have taken place in Singapore but for the settlement of the dispute or withdrawal of the claim in question;

[Deleted by Act 39 of 2017](t)the income derived on or after 20 August 1968 from interest on moneys held on deposit in an approved bank in Singapore by —

a non‑resident individual; and

a person, other than an individual, if that person does not, by itself or in association with others, carry on a business in Singapore and does not have a permanent establishment in Singapore;

[Deleted by Act 34 of 2016](ua)[Deleted by Act 34 of 2016](v)the interest received from such Asian Dollar Bonds issued on or before 31 December 2018 as may be approved in writing by the Minister or such person as the Minister may appoint if the interest is received by —

a non‑resident individual; and

a person, other than an individual, if that person does not, by itself or in association with others, carry on a business in Singapore and does not have a permanent establishment in Singapore;

the income derived from an employment exercised on board a Singapore ship, as defined in the Merchant Shipping Act 1995, if the employment is exercised substantially outside Singapore;

the income derived by a person resident in Singapore from any pension granted under any written law relating to pensions in Singapore, or from any pension paid under such other pensions scheme as may be approved by the Minister by notification in the Gazette to the extent of such amount of the pension as the Comptroller may determine relating to the period of employment of that person with the employer before 1 January 1993;

such income as may be prescribed by regulations under section 43A, 43C, 43D or 43H;

[Deleted by Act 29 of 2012](za)any dividends paid on or after 1 January 2008 by any company resident in Singapore;

any interest from debt securities;

any discount from debt securities which mature within one year from the date of issue of those securities;

any income from an annuity, except income from —

any annuity purchased by the employer of an individual in lieu of any pension or other benefit payable during the individual’s employment or upon the individual’s retirement; and

any annuity purchased under SRS;

any income from any life insurance policy, except income referred to in section 10(3);

any distribution made by the trustee of any collective investment scheme constituted as a unit trust (excluding any real estate investment trust and approved REIT exchange‑traded fund) authorised under section 286 of the Securities and Futures Act 2001 and the units of which are offered to the public for subscription, that is income or deemed to be income of the individual;

is not made out of a distribution that is in turn made out of income of the kinds mentioned in section 43(2A)(a)(i), (ii), (iii), (iv) and (v); and

is income or treated as income of the individual;

any fee or compensatory payment from securities lending or repurchase arrangements,except where such income is derived through a partnership in Singapore or is derived from the carrying on of a trade, business or profession;

any discount from debt securities;

any distribution made by any restricted Singapore scheme out of income derived from Singapore or received in Singapore on or after 17 February 2006, that is income or deemed to be income of the individual,except where such income is derived through a partnership in Singapore or is derived from the carrying on of a trade, business or profession;

by an individual, in the basis period relating to the year of assessment 2008 and any subsequent year of assessment, except where such income is derived through a partnership in Singapore or is derived from the carrying on of a trade, business or profession;

by a non‑resident person (not being an individual) if —

it does not, by itself or in association with others, carry on a business in Singapore, and does not have a permanent establishment in Singapore; and

the contract in respect of the structured product between it and the financial institution takes effect during the period from 1 January 2007 to 31 December 2026 (both dates inclusive) and, if such contract is renewed or extended, the period for which the contract is renewed or extended commences before 1 January 2027; or

by a non‑resident person (not being an individual) who carries on any operation in Singapore through a permanent establishment in Singapore if —

the funds used by that person to invest in the structured product are not obtained from the operation; and

the contract in respect of the structured product between that person and the financial institution takes effect during the period from 1 January 2007 to 31 December 2026 (both dates inclusive) and, if such contract is renewed or extended, the period for which the contract is renewed or extended commences before 1 January 2027;

the sovereign risk pooling entity is not established or operated for the object of deriving a profit and its income and capital may only be applied towards its sole object;

its capital is provided only by governments, entities wholly‑owned by governments, and organisations that are not established or operated for the object of deriving a profit;

a government (not being an insured government) or an entity or organisation mentioned in sub‑paragraph (ii) does not enjoy any risk coverage or receive any benefit in any form (including dividends) from the sovereign risk pooling entity;

benefits of any insurance provided by the sovereign risk pooling entity, as well as any distribution of the entity’s property if it ceases operation, accrue only to the insured governments.

any related party of the issuer of those securities; or

any other person where the funds used by such person to acquire those securities are obtained, directly or indirectly, from any related party of the issuer of those securities.

any related party of the issuer of those securities; or

any other person where the funds used by such person to acquire those securities are obtained, directly or indirectly, from any related party of the issuer of those securities.

any related party of the issuer of those securities; or

any other person where the funds used by such person to acquire those securities are obtained, directly or indirectly, from any related party of the issuer of those securities.

any interest derived from any qualifying project debt securities issued during the period from 1 November 2006 to 31 December 2022 (both dates inclusive);

any discount, prepayment fee, redemption premium or break cost derived from any qualifying project debt securities issued during the period from 15 February 2007 to 31 December 2022 (both dates inclusive); or

such other income directly attributable to qualifying project debt securities issued on or after a prescribed date, as may be prescribed by regulations,if 50% or more of those securities which are outstanding at any time during the life of the issue are beneficially held or funded, directly or indirectly, by related parties of the issuer of those securities.

any interest derived from any qualifying project debt securities issued during the period from 1 November 2006 to 31 December 2022 (both dates inclusive);

any discount, prepayment fee, redemption premium or break cost derived from any qualifying project debt securities issued during the period from 15 February 2007 to 31 December 2022 (both dates inclusive); or

such other income directly attributable to qualifying project debt securities issued on or after a prescribed date, as may be prescribed by regulations,if the securities are held by less than 4 persons at any time during the life of the issue, unless —

approval has been granted by the Minister or such person as he may appoint to such application;

all the persons holding the securities are companies resident in Singapore;

such companies are listed on the Singapore Exchange either on the date of issue of the securities or within 6 months from that date; and

the income from the securities received by such companies is declared to be distributable to their shareholders within 6 months from the end of the basis period in which it is received.

50% or more of those securities which are outstanding at any time during the life of the issue are beneficially held or funded, directly or indirectly, by related parties of the issuer of those securities; and

such fee, premium or cost is derived by —

any related party of the issuer of those securities; or

any other person where the funds used by such person to acquire those securities are obtained, directly or indirectly, from any related party of the issuer of those securities.

50% or more of those securities which are outstanding at any time during the life of the issue are beneficially held or funded, directly or indirectly, by related parties of the issuer of those securities; and

such income is derived by —

any related party of the issuer of those securities; or

any other person where the funds used by such person to acquire those securities are obtained, directly or indirectly, from any related party of the issuer of those securities.

50% or more of those securities which are outstanding at any time during the life of the issue are beneficially held or funded, directly or indirectly, by related parties of the issuer of those securities; and

such income is derived by —

any related party of the issuer of those securities; or

any other person where the funds used by such person to acquire those securities are obtained, directly or indirectly, from any related party of the issuer of those securities.

any interest, discount, prepayment fee, redemption premium or break cost from qualifying debt securities issued on or after 28 June 2013; or

such other income, directly attributable to qualifying debt securities as may be prescribed by regulations under that provision,that is derived on or after the date on which the tenure of any portion of those qualifying debt securities is shortened to less than 10 years from the date of their issue, where the shortening of the tenure occurs under such circumstances as may be prescribed by regulations made under that provision.

any related party of the issuer of those securities; or

any other person where the funds used by such person to acquire those securities are obtained, directly or indirectly, from any related party of the issuer of those securities.

any outgoings and expenses incurred by the entity in the production of its income for any year of assessment, and allowable under this Act, may only be deducted against its income for that year of assessment, and any excess of such outgoings and expenses over the income must be disregarded; and

the allowances under sections 19, 19A, 20, 21 and 22 relating to the production of its income for a year of assessment may only be deducted against that income, and any excess of such allowances over the income must be disregarded.

the emoluments received by a director of a company; or

the gains or profits of public entertainers, as defined in section 40A, whose visits are not substantially supported from public funds of the government of another country.

by any individual who is not resident in Singapore; and

on or after 1 January 2004 by any individual who is resident in Singapore if the Comptroller is satisfied that the tax exemption would be beneficial to the individual, but excludes such income received by the individual through a partnership in Singapore.

any dividend derived from any territory outside Singapore;

any profit derived from any trade or business carried on by a branch in any territory outside Singapore of a company resident in Singapore; and

any income derived from any professional, consultancy and other services rendered in any territory outside Singapore only if the Comptroller is satisfied that the income is derived, for the purposes of this Act, from outside Singapore,and received in Singapore —

on or after 1 June 2003 by any person, not being an individual, resident in Singapore;

during 1 June 2003 to 31 December 2003 (both dates inclusive) by any individual resident in Singapore; and

on or after 1 January 2004 by any individual resident in Singapore through a partnership in Singapore.

the income is subject to tax of a similar character to income tax (by whatever name called) under the law of the territory from which the income is received;

at the time the income is received in Singapore by the person resident in Singapore, the highest rate of tax of a similar character to income tax (by whatever name called) levied under the law of the territory from which the income is received on any gains or profits from any trade or business carried on by any company in that territory at that time is not less than 15%; and

the Comptroller is satisfied that the tax exemption would be beneficial to the person resident in Singapore.

where the company is resident in the territory from which the dividends are received, the tax paid in that territory by the company in respect of its income out of which the dividends are paid; and

the tax paid on the dividends in the territory from which the dividends are received.

exempt from tax wholly or in part; or

provide that tax at such concessionary rate of tax be levied and paid on,the income received by a person resident in Singapore from such source in any country outside Singapore as may be specified in the order.

the trustee of a real estate investment trust; or

a company incorporated in Singapore the share capital of which is, on the commencement of the order, 100% owned by the trustee of a real estate investment trust,applies on or after that date (and despite anything in the order) only to income described in subsection (12B).

relating to any immovable property situated outside Singapore that is acquired (directly or indirectly) by the trustee or the company before 1 January 2026; and

derived, either at a time the trustee or the company beneficially owns (directly or indirectly) the property, or from the disposal by the trustee or the company of its interest in that property.

be either general or specific;

prescribe the conditions subject to which the income will be exempt from tax or be taxed at a concessionary rate of tax;

provide that the Minister may require all or any of the conditions referred to in paragraph (b) to be complied with to the Comptroller’s satisfaction;

prescribe a condition requiring the person to satisfy the Comptroller that all or any of the conditions referred to in paragraph (b) have been complied with before the income is received in Singapore.

Singapore Government securities issued during the period from 28 February 1998 to 31 December 2023 (both dates inclusive);

bonds, notes, commercial papers, certificates of deposits and AT1 instruments within the meaning of section 10I(2), which are arranged in accordance with regulations made for this purpose —

by any financial institution in Singapore and issued during the period from 28 February 1998 to 31 December 2013 (both dates inclusive);

by any approved bond intermediary and issued —

during the period from 27 February 1999 to 31 December 2023 (both dates inclusive) under any prescribed programme the arrangement of which is completed on or before 31 December 2003; or

during the period from 27 February 1999 to 31 December 2003 (both dates inclusive) in any other case;

by any financial sector incentive (bond market) company and issued during the period from 1 January 2004 to 31 December 2018 (both dates inclusive); or

by any financial sector incentive (standard tier) company or financial sector incentive (capital market) company and issued during the period from 1 January 2014 to 31 December 2023 (both dates inclusive);

Islamic debt securities which are arranged in accordance with regulations made for this purpose —

by any financial institution in Singapore and issued during the period from 1 January 2005 to 31 December 2013 (both dates inclusive);

by any financial sector incentive (bond market) company and issued during the period from 1 January 2005 to 31 December 2018 (both dates inclusive); or

by any financial sector incentive (standard tier) company or financial sector incentive (capital market) company and issued during the period from 1 January 2014 to 31 December 2023 (both dates inclusive); or

debt securities whose values are derived from insured loss events underlying them, that are issued by a Special Purpose Reinsurance Vehicle during the period from 20 December 2018 to 31 December 2023 (both dates inclusive), where at least 20% of the issue costs for the issue are required to be paid to persons or partnerships carrying on any trade, business or profession in Singapore,but, unless otherwise approved by the Minister or such person as he or she may appoint, excludes any debt securities issued on or after 10 May 1999 and any Islamic debt securities issued on or after 1 January 2005 which, during its primary launch —

are issued to less than 4 persons; and

50% or more of the issue of debt securities or Islamic debt securities is beneficially held or funded, directly or indirectly, by related parties of the issuer of those debt securities or Islamic debt securities;

which are arranged in accordance with regulations made for this purpose —

by any financial institution in Singapore and issued during the period from 1 November 2006 to 31 December 2013 (both dates inclusive);

by any financial sector incentive (bond market) company or financial sector incentive (project finance) company and issued during the period from 1 November 2006 to 31 December 2022 (both dates inclusive); or

by any financial sector incentive (standard tier) company or financial sector incentive (capital market) company and issued during the period from 1 January 2014 to 31 December 2022 (both dates inclusive);

the interest and other income directly attributable to which are funded primarily by cash flows from an infrastructure asset or project prescribed by regulations (called in this definition a prescribed asset or project); and

the proceeds from the issue of which are only used to acquire, develop or invest in a prescribed asset or project, or to refinance a previous borrowing which was only used for that purpose; where the gearing ratio of such prescribed asset or project is approved by the Minister or such person as he or she may appoint in a case where the debt securities are issued by a person in Singapore or the prescribed asset or project is in Singapore,but does not include, except with the approval of the Minister or such person as he may appoint (which approval may be subject to such conditions as the Minister may impose), any debt securities —

which are issued to less than 4 persons; or

50% or more of the issue of which is beneficially held or funded, directly or indirectly, by related parties of the issuer of those debt securities;

it may not be repaid in full and the return from which is, partly or wholly, determined by the performance of any embedded derivative instrument; and

its repayment may be in money or money’s worth,but does not include any sum paid in respect of any debt securities, units of a real estate investment trust, units of a unit trust, loan, stand‑alone financial derivative or such other financial product as the Minister may by regulations prescribe;

an umbrella VCC that holds securities for one sub‑fund is treated as a different person from the same umbrella VCC that holds securities for another sub‑fund;

an umbrella VCC that holds securities for one sub‑fund is considered a company that satisfies subsection (2D)(e) and (f) if —

the umbrella VCC is resident in Singapore; and

the sub‑fund is listed on the Singapore Exchange on the date of issue of the securities or within 6 months from that date;

income that is received by an umbrella VCC from securities held by it for one sub‑fund satisfies subsection (2D)(g) if the income is declared to be distributable to holders of its shares in respect of that sub‑fund within 6 months from the end of the basis period in which the income is received.