Clause 17

by inserting, immediately after the words “feeder fund,” in subsection (1), “SPV,”; (b)by deleting the word “and” at the end of subsection (1)(c)(ii);

by deleting the comma at the end of sub‑paragraph (iii) of subsection (1)(c) and substituting a semi‑colon, and by inserting immediately thereafter the following sub‑paragraphs:“(iv)an approved eligible SPV of the structure, where the eligible SPV is not one mentioned in sub‑paragraphs (v), (vi) and (vii);

a partner of an approved eligible SPV of the structure, where the eligible SPV is a partnership (including a limited partnership and a limited liability partnership);

the trustee of an approved eligible SPV of the structure, where the eligible SPV is a trust fund; and

the taxable entity of an approved eligible SPV of the structure, where the eligible SPV is not a legal entity,”;

by deleting the word “and” at the end of subsection (1)(d)(ii);

by deleting the comma at the end of sub‑paragraph (iii) of subsection (1)(d) and substituting a semi‑colon, and by inserting immediately thereafter the following sub‑paragraphs:“(iv)an approved eligible SPV of the structure, where the eligible SPV is not one mentioned in sub‑paragraphs (v), (vi) and (vii);

a partner of an approved eligible SPV of the structure, where the eligible SPV is a partnership (including a limited partnership and a limited liability partnership);

the trustee of an approved eligible SPV of the structure, where the eligible SPV is a trust fund; and

the taxable entity of an approved eligible SPV of the structure, where the eligible SPV is not a legal entity,”;

by deleting the words “31st March 2019” in subsections (2) and (2A) and substituting in each case the words “31st December 2024”;

by deleting subsection (2B) and substituting the following subsections:“(2B) Approval under subsection (1)(c)(i) and (d)(i) may be granted during the period from 1 April 2015 to 31 December 2024 (both dates inclusive).(2C) Approval under subsection (1)(c)(ia), (ib) and (ic) may be granted during the period from 20 February 2018 to 31 December 2024 (both dates inclusive).(2D) Approval under subsection (1)(c)(ii) and (iii) and (d)(ii) and (iii) may be granted during the period from 1 April 2015 to 18 February 2019 (both dates inclusive).(2E) Approval under subsection (1)(c)(iv), (v), (vi) and (vii) and (d)(iv), (v), (vi) and (vii) may be granted during the period from 19 February 2019 to 31 December 2024 (both dates inclusive).”;

by deleting the words “or 2nd tier SPV” in subsections (3) and (4)(a), (b) and (ca) and substituting in each case the words “, 2nd tier SPV or eligible SPV”;

by inserting, immediately after the definition of “designated unit trust” in subsection (5), the following definition:“ “eligible SPV”, in relation to a master‑feeder fund‑SPV structure or a master fund‑SPV structure, means a special purpose vehicle where the net gains, profits or other benefits of all investments held by the vehicle are to go (whether directly or indirectly) to the master fund of the structure, or the master fund and one or more of the following:

a prescribed person under section 13CA;

an approved company under section 13R;

an approved person, or an approved master fund, an approved feeder fund, an approved 1st tier SPV, an approved 2nd tier SPV or an approved eligible SPV of any structure mentioned in subsection (1);

a prescribed sovereign fund entity or an approved foreign government‑owned entity under section 13Y;

a person (excluding an individual and a Hindu joint family) —

that is not resident in Singapore;

that does not have a permanent establishment in Singapore (other than a fund manager);

that does not carry on a business in Singapore;

that is not set up solely for the purpose of avoiding or reducing the payment of any tax or penalty under this Act; and

that carries on outside Singapore substantial business activity for a genuine commercial reason;

a trust fund —

the trustee of which is not resident in Singapore or a citizen of Singapore;

the trustee of which does not (in its capacity as such trustee) have a permanent establishment in Singapore other than a fund manager for that trust fund;

the trustee of which does not carry on any business in Singapore other than acting as such trustee; (iv)the trustee of which (in its capacity as such trustee) carries on outside Singapore substantial business activity for a genuine commercial reason; and

that is not set up solely for the purpose of avoiding or reducing the payment of any tax or penalty under this Act; (g)a partnership (including a limited partnership and a limited liability partnership) —

none of the partners of which is resident in Singapore;

that does not have a permanent establishment in Singapore (other than a fund manager);

that does not carry on a business in Singapore;

that is not set up solely for the purpose of avoiding or reducing the payment of any tax or penalty under this Act; and

that carries on outside Singapore substantial business activity for a genuine commercial reason; (h)an investment vehicle that is not a legal person —

the taxable entity of which is the custodian of investments held by it;

the taxable entity of which is not a resident in Singapore or a citizen of Singapore;

the taxable entity of which (in its capacity as custodian of investments held by the investment vehicle) does not have a permanent establishment in Singapore other than a fund manager for that investment vehicle;

the taxable entity of which does not carry on any business in Singapore other than acting as such custodian; (v)the taxable entity of which carries on outside Singapore substantial business activity for a genuine commercial reason; and

that is not set up solely for the purpose of avoiding or reducing the payment of any tax or penalty under this Act;”;

by deleting the definition of “special purpose vehicle” or “SPV” in subsection (5) and substituting the following definition:“ “special purpose vehicle” or “SPV” —

in relation to a master-feeder fund‑SPV structure, means an investment vehicle whose only activity is the holding of investments for other investment vehicles or persons which must include the master and feeder funds of the structure; or

in relation to a master fund‑SPV structure, means an investment vehicle whose only activity is the holding of investments for other investment vehicles or persons which must include the master fund of the structure;”;

by deleting the words “and a feeder fund” in the definition of “taxable entity” in subsection (5) and substituting the words “, a feeder fund and an SPV”;

by deleting the semi‑colon at the end of subsection (6)(b)(iii) and substituting a full‑stop; and

by deleting paragraph (c) of subsection (6).