Clause 11

in subsection (1), replace “prescribed by regulations” with “prescribed by regulations,”;

in subsection (1), after “or master fund‑SPV structure,”, insert “or specified from time to time by the Minister or an authorised body and either notified to the holder of the letter of approval or published in a manner that the Minister or authorised body reasonably believes will bring the conditions to the notice of the holder of the letter of approval,”;

in subsections (2), (2A), (2B), (2C) and (2E), replace “2024” with “2029”;

after subsection (2E), insert —“(2F) An approval under subsection (1) is subject to such conditions as the Minister or an authorised body may impose.”;

after subsection (2F) (as inserted by paragraph (d)), insert —“(2G) The Minister or an authorised body may at any time add, vary or delete a condition of an approval under subsection (2F), including (to avoid doubt) an approval given before the date of commencement of section 11(e) of the Income Tax (Amendment) Act 2024.(2H) Any addition, variation or deletion of a condition under subsection (2G) must be given to the holder of the letter of approval or published in a manner that the Minister or authorised body reasonably believes will bring the addition, variation or deletion to the attention of the holder of the approval.”;

in subsection (3), replace “and 13O” with “, 13O and 13OA”;

in subsection (4)(cb), delete “and” at the end;

in subsection (4), after paragraph (cb), insert —“(cc)provide for the revocation, or the suspension for a period specified by the Minister or an authorised body, of an approval granted under subsection (1) (including one that is granted before the date of commencement of the regulations) for non‑compliance with a condition of the approval, and for any revocation to take effect from any date, including (if it is just and reasonable to do so) —

a date before the date of the non‑compliance with the condition; or

if the condition is to be complied with over a period of time, before the date of commencement of that period; and”;

after subsection (4), insert —“(4A) To avoid doubt, where —

an exemption had been allowed under this section on the income of any approved person or person (including a company), trustee, partner, taxable entity, 1st tier SPV, 2nd tier SPV or eligible SPV (each called X);

the exemption would not have been allowed had a person, fund or structure not been approved under subsection (1) on the date the income accrued to or was derived or received by X; and

the approval is revoked under regulations made under subsection (4)(cc) with effect from or before that date,the Comptroller may make an assessment or additional assessment under section 74 on X.(4B) Where the approval of a person, fund or structure under subsection (1) is suspended pursuant to regulations made under subsection (4)(cc), the person, fund or structure is treated as not approved under subsection (1) during the period of the suspension.”; and

in subsection (5), in the definition of “eligible SPV”, after paragraph (b), insert —“(ba)an approved limited partnership under section 13OA;”.