Clause 19

in subsections (1), (2) and (3), replace “2025” with “2028”;

after subsection (1), insert —“(1A) For the purpose of ascertaining the income of a person —

who is a qualifying person for any year of assessment between the years of assessment 2024 and 2028 (both years inclusive); and

who carries on a trade or business during the basis period for that year of assessment,there is allowed in respect of all of the person’s trades and businesses, in addition to the deduction allowed under section 14 or 14C (as the case may be) and in lieu of subsection (1), a deduction for expenditure incurred during that basis period for the purposes of those trades and businesses on the licensing from another person of any qualifying intellectual property rights, computed in accordance with the formulawhere A is the lower of the following:

the expenditure incurred during that basis period; (b)$400,000.(1B) Despite subsection (1A) and section 19B, where the qualifying person has, during the basis period for any year of assessment between the years of assessment 2024 and 2028 (both years inclusive), incurred both —

expenditure on the licensing from another person of any qualifying intellectual property rights; and

expenditure on the acquisition of any intellectual property rights,the total of the expenditure which may be given a deduction under subsection (1A) and the expenditure which may be given an allowance under section 19B(1AD), must not exceed $400,000 for that year of assessment.(1C) In this section, a person is a qualifying person for a year of assessment if —

where the person is a company that is not part of a group — the person derives less than $500 million in gross revenue from all of its trades and businesses in the basis period for that year of assessment;

where the person is a company that is part of a group — all the entities in the group derive a total of less than $500 million in gross revenue from all of the entities’ trades and businesses in that basis period;

where the person is an individual proprietor — the person derives less than $500 million in gross revenue in that basis period from all of the person’s trades and businesses that are carried on through one or more individual proprietorships;

where the person is a partner of a partnership, and either the partnership is under the control of a single partner who is an individual or no single partner has control over the partnership — the partnership derives less than $500 million in gross revenue from all of the partnership’s trades and businesses in that basis period; or

where the person is a partner of a partnership, and the partnership is under the control of a single partner that is a company — the partnership, the company and all other entities in the group of which the partnership and the company are parts derive a total of less than $500 million in gross revenue from all of their trades and businesses in that basis period.(1D) In subsection (1C)(d) and (e), whether or not a partnership is under the control of a partner is determined in accordance with FRS 110.(1E) In subsections (1C) and (1D) —“FRS 110” means the financial reporting standard known as Financial Reporting Standard 110 (Consolidated Financial Statements) that is treated as made by the Accounting Standards Committee under Part 3 of the Accounting Standards Act 2007, as amended from time to time;“group” means a group of entities (whether incorporated or registered in Singapore or elsewhere) comprising a parent and its subsidiaries within the meaning of FRS 110.”;

in subsections (2) and (3), replace “of subsection (1)” with “of subsections (1) and (1A)”;

in subsections (2) and (3), replace “in subsection (1)” with “in subsection (1), or the amount computed in accordance with subsection (1A) as qualified by subsection (1B), as the case may be”; and

replace subsection (8) with —“(8) In this section —“expenditure incurred on the licensing from another person of qualifying intellectual property rights” means the licence fees but excludes —

expenditure for the transfer of ownership of any of those rights; and

legal fees and other costs related to the licensing of such rights; “individual proprietor” has the meaning given by section 2(1) of the Business Names Registration Act 2014.”.