Clause 8

by inserting, immediately after the words “carrying on” in subsection (1A), the words “offshore life business or”;

by deleting the words “dividends and interest” in paragraph (a) of the proviso to subsection (2) and substituting the words “or from such dividends and interest as may be specified in those regulations”;

by inserting, immediately after subsection (3), the following subsection:“(3A) In the case of a life insurance company which has income subject to the concessionary rate of tax prescribed by regulations made under section 43C, in ascertaining the income for the purposes of those regulations —

no income other than such dividends and interest as may be specified in those regulations shall be included;

income in respect of such dividends and interest shall be apportioned in such manner as may be prescribed by those regulations; and

any item of expenditure not directly attributable to that business shall be apportioned in such manner as may be prescribed in those regulations.”; and

by deleting subsection (5) and substituting the following subsection:“(5) For the purposes of this section and section 43C —“offshore life business” means the business of insuring or reinsuring the liability under any of the following life policies: (a)in relation to direct life insurance, a life policy where, at the date of issue of the policy, the policy owner is not resident in Singapore nor a permanent establishment in Singapore and does not have any address in Singapore for communicating with the insurance company about the policy;

in relation to facultative life reinsurance, a policy issued to reinsure liability under any life policy referred to in paragraph (a); and

in relation to treaty life reinsurance —

a reinsurance policy where the ceding party is a company incorporated outside Singapore and not resident in Singapore, or is not a permanent establishment in Singapore; or

a reinsurance policy where liabilities in respect of policies referred to in paragraph (a) are ceded by a party which is a company incorporated and resident in Singapore or a permanent establishment in Singapore;“offshore risks” means any risk outside Singapore and —

in relation to direct general insurance or facultative general reinsurance, the insured is not a person resident in Singapore or a permanent establishment in Singapore; and

in relation to treaty general reinsurance, not less than 75% of the total risk in terms of gross premiums is outside Singapore,and where any such risk is in transit in Singapore, it shall be deemed to be outside Singapore.”.