Clause 32

by inserting, immediately after subsection (2), the following subsection:“(2AA) Subsection (2) does not apply to a trust that is a REIT exchange‑traded fund unless it is an approved REIT exchange‑traded fund.”;

by deleting the word “or” at the end of subsection (2A)(b);

by inserting, immediately after paragraph (b) of subsection (2A), the following paragraph:“(ba)in the case of an approved REIT exchange‑traded fund, any income from any trade or business carried on by its trustee, other than a distribution in cash received in the period between 1 July 2018 and 31 March 2020 (both dates inclusive) from a real estate investment trust, that is in turn made out of any income mentioned in paragraph (a)(i) to (v); or”;

by inserting, immediately after subsection (2B), the following subsection:“(2C) To avoid doubt, subsection (2) (read with subsection (2A)(ba)) does not affect the operation of section 35(12) in relation to an approved REIT exchange‑traded fund that is also a designated unit trust within the meaning of section 35(14).”;

by inserting, immediately after subsection (3B), the following subsection:“(3C) Despite anything in this Act, tax at the rate of 10% is levied and must be paid on the gross amount of any distribution by a trustee of an approved REIT exchange‑traded fund that is —

made out of a distribution by a real estate investment trust that is in turn made out of income of the kinds mentioned in subsection (2A)(a)(i), (ii), (iii), (iv) and (v);

made during the period from 1 July 2018 to 31 March 2020 (both dates inclusive); and

made to a person (other than an individual) not resident in Singapore —

that does not have any permanent establishment in Singapore; or

that carries on any operation in Singapore through a permanent establishment in Singapore, where the funds used by that person to acquire the units in that approved REIT exchange‑traded fund are not obtained from that operation.”;

by deleting subsections (6) and (6A) and substituting the following subsections:“(6) Despite subsection (1) but subject to subsection (6C), tax as described in subsection (6A) or (6B) (as the case may be) is levied and must be paid for each year of assessment upon the chargeable income of every company or body of persons.(6A) For the purposes of subsection (6), the tax that is levied —

in the case of a company, for the years of assessment 2008 to 2019 (both years inclusive); and

in the case of a body of persons, for the years of assessment 2010 to 2019 (both years inclusive),is tax at the rate prescribed in subsection (1)(a) on every dollar of the chargeable income, except that —

for every dollar of the first $10,000 of the chargeable income, only 25% is chargeable with tax; and

for every dollar of the next $290,000 of the chargeable income, only 50% is chargeable with tax.(6B) For the purposes of subsection (6), the tax that is levied for the year of assessment 2020 and subsequent years of assessment, is tax at the rate prescribed in subsection (1)(a) on every dollar of the chargeable income, except that —

for every dollar of the first $10,000 of the chargeable income, only 25% is chargeable with tax; and

for every dollar of the next $190,000 of the chargeable income, only 50% is chargeable with tax.(6C) Despite subsections (1) and (6), where, in any of the first 3 years of assessment falling in or after the year of assessment 2008 of a company, the company is a qualifying company, then for that year of assessment tax as described in subsection (6D) is levied and must be paid upon the chargeable income of the company.(6D) For the purposes of subsection (6C), the tax that is levied is tax at the rate prescribed in subsection (1)(a) on every dollar of the chargeable income, except that —

for the years of assessment 2008 to 2019 (both years inclusive) —

every dollar of the first $100,000 of the chargeable income is exempt from tax; and

for every dollar of the next $200,000 of the chargeable income, only 50% is chargeable with tax; and

for the year of assessment 2020 and subsequent years of assessment —

for every dollar of the first $100,000 of the chargeable income, only 25% is chargeable with tax; and

for every dollar of the next $100,000 of the chargeable income, only 50% is chargeable with tax.”;

by inserting, immediately before the definition of “approved sub‑trust” in subsection (10), the following definition:“ “approved REIT exchange‑traded fund” means a REIT exchange‑traded fund that is approved by the Comptroller for the purposes of subsection (2);”; and

by inserting, immediately after the definition of “real estate investment trust” in subsection (10), the following definition:“ “REIT exchange‑traded fund” means a collective investment scheme authorised under section 286 of the Securities and Futures Act and listed on the Singapore Exchange, and that invests or proposes to invest only in —

real estate investment trusts; and

any entity, trust or other arrangement that invests or proposes to invest in immovable property and immovable property‑related assets, and is listed on a stock exchange outside Singapore;”.