Singapore legislation
Clause 30
Clause 30
Amendment of section 43
Section 43 of the principal Act is amended —
by deleting the words “March 2020” in subsections (2A)(ba), (3B) and (3C)(b) and substituting in each case the words “December 2025”; and
by inserting, immediately after subsection (3C), the following subsections:“(3D) In the application of subsection (3B) to a distribution mentioned in that subsection made during the period from 1 July 2019 to 31 December 2025 (both dates inclusive) to a person mentioned in subsection (3F) with a fund manager in Singapore, that fund manager is not considered a permanent establishment in Singapore of that person.(3E) In the application of subsection (3C) to a distribution mentioned in that subsection made during the period from 1 July 2019 to 31 December 2025 (both dates inclusive) to a person mentioned in subsection (3F) with a fund manager in Singapore, that fund manager is not considered a permanent establishment in Singapore of that person. (3F) Subsection (3D) or (3E) applies to a distribution made to any of the following persons or entities that is not resident in Singapore:
a prescribed person (other than an individual) under section 13CA;
an approved person under section 13X;
a person (not being an individual, a body of persons or a Hindu joint family) that is the approved master fund or an approved feeder fund of an approved master‑feeder fund structure under section 13X;
a partner of a partnership (including a limited partnership and a limited liability partnership), where the partnership is the approved master fund or an approved feeder fund of an approved master‑feeder fund structure under section 13X;
a trustee of a trust fund where the trust fund is the approved master fund or an approved feeder fund of an approved master‑feeder fund structure under section 13X;
a taxable entity in relation to the approved master fund or an approved feeder fund of an approved master‑feeder fund structure under section 13X, where the master fund or feeder fund is not a legal entity;
a company, a trustee of a trust fund or a partner of a limited partnership, where the company, trust fund or limited partnership is an approved feeder fund of an approved master‑feeder fund‑SPV structure under section 13X;
a person (not being a company, an individual or a Hindu joint family) that is an approved feeder fund of an approved master‑feeder fund‑SPV structure under section 13X;
a partner of a partnership (excluding a limited partnership but including a limited liability partnership), where the partnership is an approved feeder fund of an approved master‑feeder fund‑SPV structure under section 13X;
a taxable entity in relation to an approved feeder fund of an approved master‑feeder fund‑SPV structure under section 13X, where the feeder fund is not a legal entity;
an approved 1st tier SPV of an approved master‑feeder fund‑SPV structure under section 13X;
an approved 2nd tier SPV of an approved master‑feeder fund‑SPV structure under section 13X;
an approved eligible SPV of an approved master‑feeder fund‑SPV structure under section 13X, where the eligible SPV is not one mentioned in paragraphs (n), (o) and (p);
a partner of an approved eligible SPV of an approved master‑feeder fund‑SPV structure under section 13X, where the eligible SPV is a partnership (including a limited partnership and a limited liability partnership);
the trustee of an approved eligible SPV of an approved master‑feeder fund‑SPV structure under section 13X, where the eligible SPV is a trust fund;
the taxable entity of an approved eligible SPV of an approved master‑feeder fund‑SPV structure under section 13X, where the eligible SPV is not a legal entity;
an approved 1st tier SPV of an approved master fund‑SPV structure under section 13X; (r)an approved 2nd tier SPV of an approved master fund‑SPV structure under section 13X;
an approved eligible SPV of an approved master fund‑SPV structure under section 13X, where the eligible SPV is not one mentioned in paragraphs (t), (u) and (v);
a partner of an approved eligible SPV of an approved master fund‑SPV structure under section 13X, where the eligible SPV is a partnership (including a limited partnership and a limited liability partnership);
the trustee of an approved eligible SPV of an approved master fund‑SPV structure under section 13X, where the eligible SPV is a trust fund;
the taxable entity of an approved eligible SPV of an approved master fund‑SPV structure under section 13X, where the eligible SPV is not a legal entity; (w)a prescribed sovereign fund entity or an approved foreign government‑owned entity under section 13Y.”.