Clause 3

in subsection (5), delete “of dividend or interest”;

in subsection (8), replace paragraph (a) with —“(a)any distribution, the transferor is to be assessed at the tax rate that would have applied to the distribution had it been made directly to the transferor; or”;

in subsection (9)(b)(i), delete “or” at the end;

in subsection (9)(b)(iii), after “any”, insert “distribution of”;

in subsection (9)(b)(iii), replace the comma at the end with “; or”;

in subsection (9)(b), after sub‑paragraph (iii), insert —“(iv)any distribution of any other income that is not exempt from tax,”;

in subsection (9), replace “distribution of interest or compensatory payment” with “distribution or compensatory payment”;

after subsection (9), insert —“(9A) Section 45 applies in the manner set out in section 45G in relation to —

any distribution in respect of transferred securities that are units of a real estate investment trust or an approved REIT exchange‑traded fund; and

any compensatory payment in place of any distribution mentioned in paragraph (a),made under a securities lending or repurchase arrangement by a Singapore‑based transferee to a transferor who is not known to the trustee to be resident in Singapore, as section 45 applies in relation to a distribution by a trustee of a real estate investment trust or by a trustee of an approved REIT exchange‑traded fund to another person in accordance with section 45G(1), and for this purpose —

any reference in section 45G to a distribution is to the distribution or compensatory payment mentioned in paragraph (a) or (b);

section 45G(4) does not apply in relation to a compensatory payment mentioned in paragraph (b); and

section 45G(5) is omitted.”;

in subsection (12), before the definition of “borrowing period”, insert —“ “approved REIT exchange‑traded fund” and “real estate investment trust” have the meanings given by section 43(10);”;

in subsection (12), in the definition of “compensatory payment”, delete “of interest, dividend”;

in subsection (12), after the definition of “compensatory payment”, insert —“ “distribution”, in relation to any transferred securities, includes the distribution of any income paid under the transferred securities to the holder of the transferred securities;”;

in subsection (12), in the definition of “foreign debt securities”, replace “securities, other than stocks and shares,” with “debt securities”;

in subsection (12), replace the definition of “securities” with —“ “securities” includes —

units in a collective investment scheme, exchange‑traded fund, business trust or depository receipts; and

any securities (including units mentioned in paragraph (a)) provided as a collateral;”; and

in subsection (12), replace the definition of “Singapore‑based transferee” with —“ “Singapore‑based transferee” means a transferee —

who is resident in Singapore (except in respect of any business carried on outside Singapore through a permanent establishment outside Singapore); or

who is not resident in Singapore but enters into the securities lending or repurchase arrangement through a permanent establishment in Singapore or for the purpose of a business carried on through a permanent establishment in Singapore;”.