Section 13E

on or after 1 April 1991 from —

the carriage of passengers, mail, livestock or goods from outside the limits of the port of Singapore by any foreign ship;

the charter of any foreign ship to any person where such ship is used by the person for the carriage of passengers, mail, livestock or goods outside the limits of the port of Singapore; and

the carriage of passengers, mail, livestock or goods by any foreign ship to Singapore solely for the purpose of transhipment;

for the year of assessment 2005 and subsequent years of assessment from —

the operation outside the limits of the port of Singapore of any dredger, seismic ship or any ship used for offshore oil or gas activity; and

the charter of any foreign dredger, foreign seismic ship, or any foreign ship used for offshore oil or gas activity to any person where such dredger, seismic ship or ship is used by the person for the person’s operation outside the limits of the port of Singapore;

for the year of assessment 2003 and subsequent years of assessment from —

towing or salvage operations carried out from outside the limits of the port of Singapore by any foreign ship; and

the charter of any foreign ship to any person where such ship is used by the person for towage and salvage operations carried out outside the limits of the port of Singapore;

for the year of assessment 2009 and subsequent years of assessment, from foreign exchange and risk management activities which are carried out in connection with and incidental to the operations described in paragraphs (a), (b) and (c);

at any time in the period between 22 February 2010 and 23 February 2015 (both dates inclusive) from the provision of ship management services to any qualifying special purpose vehicle in respect of ships owned or operated by the qualifying special purpose vehicle, unless the conditions of its approval otherwise provide;

for the year of assessment 2012 and subsequent years of assessment, from the carriage by any foreign ship of passengers, mail, livestock or goods which are shipped in Singapore, except where such carriage is only within the limits of the port of Singapore;

on or after 1 June 2011 from —

the sale of a foreign ship used for a prescribed purpose;

the assignment to another of all its rights as the buyer under a contract for the construction of a ship for a prescribed purpose that, at the time of assignment, is intended to be a foreign ship to be used for that or any other prescribed purpose; or

the sale of all of the issued ordinary shares in a special purpose company of the approved international shipping enterprise where, at the time of the sale of the shares, the special purpose company —

owns any foreign ship that is used for a prescribed purpose;

is the buyer under a contract for the construction of a foreign ship for a prescribed purpose that is intended to be used for that or any other prescribed purpose;

owns a Singapore ship within the meaning of section 13A(16) or a ship that is provisionally registered under the Merchant Shipping Act 1995; or

is the buyer under a contract for the construction of a ship that, at the time of the sale, is intended to be registered or is provisionally registered under the Merchant Shipping Act 1995;

at any time during the period from 24 February 2015 to 18 February 2020 (both dates inclusive) from providing prescribed ship management services to any qualifying special purpose vehicle in respect of ships owned or operated by the qualifying special purpose vehicle, unless the conditions of its approval otherwise provide;

on or after 24 February 2015 from —

any mobilisation or holding of any ship used or to be used for offshore oil or gas activity outside the limits of the port of Singapore; or

the demobilisation of any ship after it has been so used,where the mobilisation, holding or demobilisation is undertaken by the approved international shipping enterprise itself using a foreign ship;

on or after 24 February 2015 from —

any mobilisation or holding of a foreign ship owned or operated by the approved international shipping enterprise and used or to be used for offshore oil or gas activity outside the limits of the port of Singapore; or

the demobilisation of a foreign ship owned or operated by the approved international shipping enterprise after it has been so used;

on or after 24 February 2015 from the leasing of any container (other than finance leasing) carried out in connection with its operation of foreign ships and that is incidental to such operation;

on or after 25 March 2016 from —

the operation outside the limits of the port of Singapore of any foreign ship for offshore renewable energy activity or offshore mineral activity; and

the charter of any foreign ship for offshore renewable energy activity or offshore mineral activity to any person, where such ship is used by the person for the person’s operation outside the limits of the port of Singapore;

on or after 25 March 2016 from —

the sale of a foreign ship used for offshore renewable energy activity or offshore mineral activity;

the assignment to another of all its rights as the buyer under a contract for the construction of a ship for offshore renewable energy activity or offshore mineral activity that, at the time of assignment, is intended to be a foreign ship to be used for that activity or any prescribed purpose; or

the sale of all of the issued ordinary shares in a special purpose company of the approved international shipping enterprise where, at the time of the sale of the shares, the special purpose company —

owns any foreign ship that is used for offshore renewable energy activity or offshore mineral activity; or

is the buyer under a contract for the construction of a foreign ship for that activity and that is intended to be used for that activity or any prescribed purpose;

on or after 25 March 2016 from —

any mobilisation or holding of any ship used or to be used for offshore renewable energy activity, or offshore mineral activity, outside the limits of the port of Singapore; or

the demobilisation of any ship after it has been so used,where the mobilisation, holding or demobilisation is undertaken by the approved international shipping enterprise itself using a foreign ship;

on or after 25 March 2016 from —

any mobilisation or holding of a foreign ship owned or operated by the approved international shipping enterprise and used or to be used for offshore renewable energy activity, or offshore mineral activity, outside the limits of the port of Singapore; or

the demobilisation of a foreign ship owned or operated by the approved international shipping enterprise after it has been so used;

on or after 25 March 2016 from foreign exchange and risk management activities which are carried out in connection with and incidental to an activity described in paragraph (l), (n) or (o);

on or after 29 December 2016 from foreign exchange and risk management activities that are carried out in connection with and incidental to an activity mentioned in subsection (1)(f), (h), (i) or (j);

on or after 12 December 2018 from —

the finance leasing of any foreign ship to any person where the ship is used by the person for the carriage of passengers, mail, livestock or goods outside the limits of the port of Singapore;

the finance leasing of any foreign dredger, foreign seismic ship, or any foreign ship used for offshore oil or gas activity to any person where the dredger, seismic ship or ship is used by the person for the person’s operation outside the limits of the port of Singapore;

the finance leasing of any foreign ship to any person where the ship is used by the person for towage and salvage operations carried out outside the limits of the port of Singapore; and

the finance leasing of any foreign ship for offshore renewable energy activity or offshore mineral activity to any person, where the ship is used by the person for the person’s operation outside the limits of the port of Singapore;

on or after 12 December 2018 from foreign exchange and risk management activities which are carried out in connection with and incidental to an activity mentioned in paragraph (r); and

on or after 19 February 2020 from providing prescribed ship management services to —

any qualifying special purpose vehicle of the approved international shipping enterprise or another approved international shipping enterprise; or

any qualifying shareholder of the approved international shipping enterprise,in respect of ships owned or operated by the qualifying special purpose vehicle or qualifying shareholder (as the case may be), unless the conditions of its approval otherwise provide.

any income of an approved international shipping enterprise derived before 12 December 2018 as a lessor of a foreign ship used for a prescribed purpose, under a finance lease that is treated as a sale under section 10C; or

any income of an approved international shipping enterprise that is derived as part of a business of trading in foreign ships used for a prescribed purpose, or of constructing for sale foreign ships for a prescribed purpose.

any income of an approved international shipping enterprise derived before 12 December 2018 as a lessor of a foreign ship used for offshore renewable energy activity or offshore mineral activity, under a finance lease that is treated as a sale under section 10C; or

any income of an approved international shipping enterprise that is derived as part of a business of trading in foreign ships used for either of those activities, or of constructing for sale foreign ships for either of those activities.

which is an international shipping enterprise; or

which is not but intends to become an international shipping enterprise,to be approved as an approved international shipping enterprise, and the company is deemed upon approval to be an approved international shipping enterprise.

is for such period not exceeding 10 years from the date of its approval as the Minister or such person as the Minister may appoint may specify, except that the Minister or such person as the Minister may appoint may extend the period so specified for such further periods, not exceeding 10 years at a time, as the Minister or appointed person thinks fit; or

if, at the time of its approval, the company does not, in the opinion of the Minister or such person as he may appoint, satisfy such qualifying conditions as the Minister or person may determine for the purposes of paragraph (a), is for such period not exceeding 5 years from the date of its approval as the Minister or person may specify.

must be taken into account even if no claim for those allowances has been made; and

may only be deducted against the income referred to in subsection (1), and the balance of those allowances is not available as a deduction against any other income, except that any balance remaining unabsorbed at the end of the tax exempt period is available as a deduction against any other income for the year of assessment which relates to the basis period in which the tax exemption ceases and for any subsequent year of assessment in accordance with section 23.

must be deducted in accordance with section 37; and

may only be deducted against the income referred to in any of those paragraphs, and the balance of such loss is not available as a deduction against any other income, except that any balance remaining unabsorbed at the end of the tax exempt period is available as a deduction against any other income for the year of assessment which relates to the basis period in which the tax exemption ceases and for any subsequent year of assessment in accordance with section 37.

owning or operating ships; or

which has a qualifying special purpose vehicle which owns or operates ships;

the carriage of passengers, mail, livestock or goods;

dredging, seismic, or offshore oil or gas activity;

a towing or salvage operation; or

the mobilisation, holding or demobilisation of another ship;

any operation mentioned in subsection (1)(a), (b), (c), (f), (i) and (j);

any operation of a Singapore ship as defined in section 13A(16);

any operation or activity mentioned in subsection (1)(l), (n) or (o) that takes place on or after 25 March 2016; or

any operation or activity mentioned in subsection (1)(r) that takes place on or after 12 December 2018.

an approved company —

which is incorporated and resident in Singapore; and

at least 50% of the total number of the issued ordinary shares of which are beneficially owned, whether directly or indirectly, by —

the entity; or

a company which beneficially owns (whether directly or indirectly) at least 50% of the total number of the issued ordinary shares of the entity;

an approved company —

which is incorporated outside Singapore; and

at least 25% of the total number of the issued ordinary shares of which are beneficially owned, whether directly or indirectly, by the entity;

an approved partnership —

which is registered or formed outside Singapore; and

of which the entity is entitled, whether directly or indirectly, to at least 25% of its income;

an approved company —

which is incorporated and resident in Singapore, and at least 50% of the total number of the issued ordinary shares of which are beneficially owned directly by another company which is a qualifying special purpose vehicle by virtue of paragraph (a)(ii)(B); or

which is incorporated outside Singapore, and at least 25% of the total number of the issued ordinary shares of which are beneficially owned directly by another company which is a qualifying special purpose vehicle by virtue of paragraph (a)(ii)(B);

an approved partnership which is registered or formed outside Singapore and one of the partners of which is a company which is a qualifying special purpose vehicle by virtue of paragraph (a)(ii)(B), and is entitled to at least 25% of its income; or

any other partnership or company that is approved under subsection (8) as a qualifying special purpose vehicle of the entity, so long as it satisfies the conditions imposed under that subsection.

that is incorporated and resident in Singapore; and

that beneficially owns (whether directly or indirectly) at least 50% of the total number of issued ordinary shares of the approved international shipping enterprise.