Clause 12

a trust that is constituted on or after 1st April 2019;

a company that is incorporated on or after 1st April 2019;

a trust that —

is constituted before 1st April 2019; and

in the basis period in which 31st March 2019 falls, is not a philanthropic purpose trust that —

has a foreign account; and

is administered by a trustee company in Singapore; or

a company that —

is incorporated before 1st April 2019; and

in the basis period in which 31st March 2019 falls, is not an eligible holding company established for the purposes of a philanthropic purpose trust which satisfies the requirements in paragraph (c)(ii)(A) and (B).(6) Where, in any basis period beginning on or after 1st April 2019, a trust or company does not satisfy the applicable requirement referred to in subsection (7), then this section shall not apply to the trust or company for the year of assessment to which that basis period relates, and for every subsequent year of assessment even if that requirement is satisfied in the basis period for the subsequent year of assessment.(7) In subsection (6), the requirement is —

in the case of the trust, that it is a philanthropic purpose trust that has a foreign account and is administered by a trustee company in Singapore; or

in the case of the company, that it is an eligible holding company established for the purposes of a philanthropic purpose trust which satisfies all of the requirements in paragraph (a).(8) Where, in any basis period beginning on or after 1st April 2019, the trustee company which administers a philanthropic purpose trust fails to comply with any of the regulations under subsection (1), then this section shall not apply to the trust or the eligible holding company established for the purposes of the trust for the year of assessment to which that basis period relates, and for every subsequent year of assessment even if those regulations are satisfied in the basis period for the subsequent year of assessment.”.