Singapore legislation

Clause 7

of Finance (Income Taxes) Bill

Clause 7

Amendment of section 13E

(1)

In the ITA, in section 13E —

(a)

in subsection (1)(l), replace “on or after 25 March 2016” with “during the period from 25 March 2016 to 18 February 2025 (both dates inclusive)”;

(b)

in subsection (1)(l)(i) and (ii), delete “or offshore mineral activity”;

(c)

in subsection (1)(l)(i), replace “and” at the end with “or”;

(d)

in subsection (1), after paragraph (l), insert —“(la)on or after 19 February 2025 from —

(i)

the operation outside the limits of the port of Singapore of any foreign ship for renewable energy activity; or

(ii)

the charter of any foreign ship for renewable energy activity to any person, where such ship is used by the person for the person’s operation outside the limits of the port of Singapore;

(lb)on or after 25 March 2016 from —

(i)

the operation outside the limits of the port of Singapore of any foreign ship for offshore mineral activity; or

(ii)

the charter of any foreign ship for offshore mineral activity to any person, where such ship is used by the person for the person’s operation outside the limits of the port of Singapore;”;

(e)

in subsection (1)(m), replace “on or after 25 March 2016” with “during the period from 25 March 2016 to 18 February 2025 (both dates inclusive)”;

(f)

in subsection (1)(m)(i), (ii) and (iii)(A), delete “or offshore mineral activity”;

(g)

in subsection (1), after paragraph (m), insert —“(ma)on or after 19 February 2025 from —

(i)

the sale of a foreign ship used for renewable energy activity;

(ii)

the assignment to another of all its rights as the buyer under a contract for the construction of a ship for renewable energy activity that, at the time of assignment, is intended to be a foreign ship to be used for that activity or any prescribed purpose; or

(iii)

the sale of all of the issued ordinary shares in a special purpose company of the approved international shipping enterprise where, at the time of the sale of the shares, the special purpose company —

(A)

owns any foreign ship that is used for renewable energy activity; or

(B)

is the buyer under a contract for the construction of a foreign ship for that activity and that is intended to be used for that activity or any prescribed purpose;

(mb)on or after 25 March 2016 from —

(i)

the sale of a foreign ship used for offshore mineral activity;

(ii)

the assignment to another of all its rights as the buyer under a contract for the construction of a ship for offshore mineral activity that, at the time of assignment, is intended to be a foreign ship to be used for that activity or any prescribed purpose; or

(iii)

the sale of all of the issued ordinary shares in a special purpose company of the approved international shipping enterprise where, at the time of the sale of the shares, the special purpose company —

(A)

owns any foreign ship that is used for offshore mineral activity; or

(B)

is the buyer under a contract for the construction of a foreign ship for that activity and that is intended to be used for that activity or any prescribed purpose;”;

(h)

in subsection (1)(n), replace “on or after 25 March 2016” with “during the period from 25 March 2016 to 18 February 2025 (both dates inclusive)”;

(i)

in subsection (1)(n)(i), delete “, or offshore mineral activity,”;

(j)

in subsection (1), after paragraph (n), insert —“(na)on or after 19 February 2025 from —

(i)

any mobilisation or holding of any ship used or to be used for renewable energy activity outside the limits of the port of Singapore; or

(ii)

the demobilisation of any ship after it has been so used,where the mobilisation, holding or demobilisation is undertaken by the approved international shipping enterprise itself using a foreign ship;

(nb)on or after 25 March 2016 from —

(i)

any mobilisation or holding of any ship used or to be used for offshore mineral activity outside the limits of the port of Singapore; or

(ii)

the demobilisation of any ship after it has been so used,where the mobilisation, holding or demobilisation is undertaken by the approved international shipping enterprise itself using a foreign ship;”;

(k)

in subsection (1)(o), replace “on or after 25 March 2016” with “during the period from 25 March 2016 to 18 February 2025 (both dates inclusive)”;

(l)

in subsection (1)(o)(i), delete “, or offshore mineral activity,”;

(m)

in subsection (1), after paragraph (o), insert —“(oa)on or after 19 February 2025 from —

(i)

any mobilisation or holding of a foreign ship owned or operated by the approved international shipping enterprise and used or to be used for renewable energy activity outside the limits of the port of Singapore; or

(ii)

the demobilisation of a foreign ship owned or operated by the approved international shipping enterprise after it has been so used;

(ob)on or after 25 March 2016 from —

(i)

any mobilisation or holding of a foreign ship owned or operated by the approved international shipping enterprise and used or to be used for offshore mineral activity outside the limits of the port of Singapore; or

(ii)

the demobilisation of a foreign ship owned or operated by the approved international shipping enterprise after it has been so used;”;

(n)

in subsection (1)(p), replace “(n) or (o)” with “(lb), (n), (nb), (o) or (ob)”;

(o)

in subsection (1)(r), replace sub‑paragraph (iv) with —“(iv)the finance leasing of any foreign ship to any person where the ship is used by the person for any of the following activities outside the limits of the port of Singapore:

(A)

offshore renewable energy activity carried out before 19 February 2025; (B)renewable energy activity carried out on or after 19 February 2025; or (C)offshore mineral activity;”;

(p)

in subsection (1)(s), delete “and” at the end;

(q)

in subsection (1)(t), replace the full‑stop at the end with “; and”;

(r)

in subsection (1), after paragraph (t), insert —“(u)on or after 19 February 2025 from foreign exchange and risk management activities which are carried out in connection with and incidental to an activity mentioned in paragraph (la), (na) or (oa).”;

(s)

in subsection (1AC), replace “Subsection (1)(m) does” with “Subsection (1)(m), (ma) and (mb) does”;

(t)

in subsection (1AC)(b), replace “used for either of those activities” with “used for offshore renewable energy activity, renewable energy activity or offshore mineral activity”;

(u)

in subsection (1AC)(b), replace “foreign ships for either of those activities” with “foreign ships for any of those activities”;

(v)

in subsection (2A), replace “2026” with “2031”;

(w)

in subsection (4), replace “(l) and (n) to (s)” with “(lb), (n) to (s) and (u)”;

(x)

in subsection (4A), replace “in subsection (1)(g) or (m)” with “in subsection (1)(g), (m), (ma) or (mb)”;

(y)

in subsection (4A), replace “either subsection (1)(g) or (m)” with “subsection (1)(g), (m), (ma) or (mb)”;

(z)

in subsection (6), in the definition of “special purpose company”, in paragraph (c), replace “on or after 25 March 2016” with “during the period from 25 March 2016 to 18 February 2025 (both dates inclusive)”;

(za)in subsection (6), in the definition of “special purpose company”, in paragraph (c), delete “or” at the end;

(zb)in subsection (6), in the definition of “special purpose company”, after paragraph (c), insert —“(ca)any operation or activity mentioned in subsection (1)(la), (na) or (oa) that takes place on or after 19 February 2025;

(cb)any operation or activity mentioned in subsection (1)(lb), (nb) or (ob) that takes place on or after 25 March 2016; or”;

(zc)in subsection (7)(a), after “approved company”, insert “other than one mentioned in paragraph (b)”;

(zd)in subsection (7)(a)(i) and (d)(i), delete “incorporated and”; and

(ze)in subsection (7)(d)(i), after “Singapore”, insert “and is not one mentioned in sub‑paragraph (ii)”.

(2)

In the ITA, in section 13E —

(a)

in subsection (1)(t) (as amended by subsection (1)(q)), delete “and” at the end;

(b)

in subsection (1)(u) (as inserted by subsection (1)(r)), replace the full‑stop at the end with “; and”;

(c)

in subsection (1), after paragraph (u) (as inserted by subsection (1)(r)), insert —“(v)on or after the date of commencement of section 7(2)(c) of the Finance (Income Taxes) Act 2025, from foreign exchange and risk management activities which are carried out in connection with and incidental to an activity mentioned in paragraph (t).”; and

(d)

in subsection (4) (as amended by subsection (1)(w)), replace “, (n) to (s) and (u)” with “and (n) to (v)”.