Clause 16

in subsection (1)(a), replace “the year of assessment 2012 or any subsequent year of assessment” with “any year of assessment between the year of assessment 2012 and the year of assessment 2025 (both years inclusive)”;

after subsection (2), insert —“(2A) Where —

a special purpose vehicle has acquired treasury shares or previously issued shares in a company and, in the basis period for the year of assessment 2026 or any subsequent year of assessment, transfers those shares to any person under a stock option scheme or a share award scheme by reason of any office or employment held in Singapore by that person in the company; and

payment by the company for the shares transferred to the person has become due and payable,then the company is allowed a deduction for the relevant year of assessment of an amount referred to in subsection (2B).(2B) The amount of deduction under subsection (2A) is —

where the transferred shares are previously issued shares, the lower of the following:

the amount paid or payable by the company for the shares, less any amount paid or payable by the person for the shares, to the extent the amount so paid or payable has not been deducted from the firstmentioned amount;

the cost to the special purpose vehicle of acquiring the shares, less any amount paid or payable by the person for the shares; or

where the transferred shares are treasury shares, the cost to the company of acquiring the shares, less any amount paid or payable by the person for the shares.”;

in subsection (3), replace “subsection (2)(a)(ii) and (b)(i)(B)” with “subsections (2)(a)(ii) and (b)(i)(B) and (2B)(a)(ii)”;

in subsection (4)(c), after “subsection (1)”, insert “or (2A) (as the case may be)”;

in subsection (4)(c), in the definition of “D”, after “subsection (1)”, insert “or (2A) (as the case may be)”;

in subsection (5), replace “subsection (2)(b)(i)(C) and (ii)” with “subsections (2)(b)(i)(C) and (ii) and (2B)(b)”;

in subsection (7), replace “the subsidiary company” wherever it appears with “subsidiary X”;

in subsection (7)(a), replace “the year of assessment 2012 or any subsequent year of assessment” with “any year of assessment between the year of assessment 2012 and the year of assessment 2025 (both years inclusive)”;

in subsection (8)(a)(i) and (b)(i)(A), replace “the subsidiary company” with “subsidiary X”;

after subsection (8), insert —“(8A) Where —

a special purpose vehicle has acquired treasury shares or previously issued shares in the holding company of another company (called in this section subsidiary Y) and, in the basis period for the year of assessment 2026 or any subsequent year of assessment, transfers those shares to a person under a stock option scheme or a share award scheme by reason of any office or employment held in Singapore by that person in subsidiary Y; and

payment by subsidiary Y for the shares transferred to the person has become due and payable,then subsidiary Y is allowed a deduction for the relevant year of assessment of an amount mentioned in subsection (8B).(8B) The amount of deduction under subsection (8A) is —

where the transferred shares are previously issued shares, the lower of the following:

the amount paid or payable by subsidiary Y for the shares, less any amount paid or payable by the person for the shares, to the extent the amount so paid or payable has not been deducted from the firstmentioned amount;

the cost to the special purpose vehicle of acquiring the shares, less any amount paid or payable by the person for the shares; or

where the transferred shares are treasury shares, the lower of the following:

the amount paid or payable by subsidiary Y for the shares, less any amount paid or payable by the person for the shares, to the extent the amount so paid or payable has not been deducted from the firstmentioned amount;

the cost to the holding company of acquiring the shares, as determined in accordance with section 14L(8A), less any amount paid or payable by the person for the shares.”;

in subsection (9), replace “subsection (8)” with “subsections (8)(a)(ii) and (b)(i)(B) and (8B)(a)(ii)”;

in subsection (9), replace “the subsidiary company” with “subsidiary X or subsidiary Y (as the case may be)”;

in subsection (10)(a), delete “and” at the end;

in subsection (10)(b), replace the full‑stop at the end with “; and”;

in subsection (10), after paragraph (b), insert —“(c)a reference to subsection (2A) is a reference to subsection (8A).”;

in subsection (13), in the definition of “regular interval”, in paragraph (b)(i), replace “or subsidiary company” with “, subsidiary X or subsidiary Y”;

in subsection (13), in the definition of “relevant year of assessment”, in paragraph (a), replace “or (7)” with “, (2A), (7) or (8A)”;

in subsection (13), in the definition of “relevant year of assessment”, in paragraphs (a) and (b), replace “or subsidiary company” with “, subsidiary X or subsidiary Y”;

in subsection (13), in the definition of “special purpose vehicle”, in paragraph (a), after “subsection (1)”, insert “or (2A)”;

in subsection (13), in the definition of “special purpose vehicle”, in paragraph (a)(ii), delete “or” at the end;

in subsection (13), in the definition of “special purpose vehicle”, in paragraph (b), replace “subsidiary company referred to in that subsection” with “subsidiary X”;

in subsection (13), in the definition of “special purpose vehicle”, in paragraph (b), replace the full‑stop at the end with “; or”; and

in subsection (13), in the definition of “special purpose vehicle”, after paragraph (b), insert —“(c)in the case of subsection (8A), shares in one company within a group of companies to which both the holding company and subsidiary Y belong, are to be used for the remuneration of a person by reason of any office or employment held by that person in a company within the same group of companies.”.