Clause 28

by deleting paragraph (b) of subsection (1);

by deleting the words “incurred any debt in any trade or business” in subsection (3) and substituting the words “has any debt owed to it in respect of a trade or business outside Singapore, that was incurred”;

by inserting, immediately after the word “debt” in subsection (3)(b), the words “, or any reversal of the impairment loss,”;

by deleting the words “incurs any impairment loss from any financial asset on revenue account before its registration date” in subsection (4) and substituting the words “incurred before its registration date any impairment loss from any financial asset on revenue account acquired for the purpose of any trade or business outside Singapore”;

by deleting the words “from any financial asset on revenue account that is acquired by the company” in subsection (5) and substituting the words “, in the course of carrying on a trade or business in Singapore, from any financial asset on revenue account that was acquired by the company for the purpose of any trade or business outside Singapore”;

by inserting, immediately after the words “registration date” in subsections (7) and (8), the words “for the purpose of any trade or business outside Singapore”;

by deleting subsection (9) and substituting the following subsection:“(9) Despite anything in sections 14A, 14D, 14Q, 14S and 14U, a redomiciled company that has never, at any time before its registration date, carried on any trade or business in Singapore, may only make a claim for a deduction under any of those sections for any cost, payment or expenditure incurred or made before its registration date, if —

such cost, payment or expenditure is incurred or made for the purpose of a trade or business in Singapore; and

the company has not carried on the same trade or business outside Singapore at any time before its registration date.”;

by inserting, immediately after the word “plant” in subsection (11)(a), the words “for the purpose of any trade or business outside Singapore”;

by inserting, immediately after the words “section 19A(10)” in subsection (14)(a), the words “, for the purpose of any trade or business outside Singapore”;

by deleting paragraph (a) of subsection (17) and substituting the following paragraph:“(a)incurred capital expenditure before its registration date to acquire any intellectual property rights for the purpose of any trade or business outside Singapore; and”;

by inserting, immediately after the words “those rights for” in subsection (17)(b), the words “the purpose of”; and

by inserting, immediately after subsection (20), the following subsections:“Ascertainment of profits of insurers(20A) Where —

a body corporate incorporated outside Singapore that is registered as a redomiciled company carried on insurance business (not being life business) outside Singapore at any time before its registration date;

the redomiciled company carries on the same insurance business (not being life business) in Singapore on or after its registration date; and

the registration date of the redomiciled company falls within a period for which its gains or profits from that insurance business in Singapore are to be ascertained for the purposes of this Act,then, for the purposes of applying section 26(3) to the period mentioned in paragraph (c), the liabilities of the redomiciled company immediately before the registration date in respect of the common policies, are to be added to the beginning value mentioned in section 26(3)(b).(20B) If —

a body corporate incorporated outside Singapore that is registered as a redomiciled company carried on life business outside Singapore at any time before its registration date;

the redomiciled company carries on the same life business in Singapore on or after its registration date; and

the registration date of the redomiciled company falls within a period for which its gains or profits from that life business in Singapore are to be ascertained for the purposes of this Act,then, for the purposes of applying section 26(6) to the period mentioned in paragraph (c), the liabilities of the redomiciled company immediately before the registration date in respect of the common policies, are to be added to the beginning value mentioned in paragraphs (a)(ii) and (b)(iv) of both definitions of “onshore life insurance surplus”, and paragraphs (a)(ii) and (b)(iv) of both definitions of “offshore life insurance surplus” in section 26(12).(20C) In subsections (20A) and (20B) —

“life business” means the business of insuring or reinsuring the liability of a life policy or accident and health policy as defined in the Insurance Act (Cap. 142);

a redomiciled company carries on the same insurance business (not being life business) or life business in Singapore that it carried on outside Singapore if the policies which it assumes the risks or undertakes the liabilities of, or for which it collects or receives premiums, when carrying on life business or an insurance business (not being life business) in Singapore —

are policies that are, or are part of; or

include policies that are, or are part of,the policies which it assumed the risks or undertook the liabilities of, or for which it collected or received premiums, when carrying on life business or an insurance business (not being life business) outside Singapore; and

a reference to common policies is a reference to the policies mentioned in sub‑paragraph (b)(i) or (ii), as the case may be.”.