Singapore legislation
Regulation 5A
of Income Tax (Concessionary Rate of Tax for Financial Sector Incentive Companies) Regulations 2017
Regulation 5A
12% or 13.5% tax payable on qualifying income of financial sector incentive (trustee companies) company
Subregulation 1
Tax is payable at the rate specified in paragraph (1A)(a) or (b) on the income of a financial sector incentive (trustee companies) company from the provision of any of the following services:
trustee or custodian services in its capacity as a trustee of a trust;
trustee or custodian services in respect of bond or loan stock issues, including services for monitoring loan covenants and administering loan repayments;
trust management or administration services to —
a trustee of a trust; or
a holding company of a trust that is administered by a trustee company in Singapore;
trustee services in respect of the issue of units of a collective investment scheme, or of a business trust;
custodian services in respect of —
debt securities;
equity securities;
units in a collective investment scheme; or
units in a business trust.
Subregulation 1A
In paragraph (1), the rate is —
where the effective date of the company’s approval or the effective date of the extension of its approval as a financial sector incentive (trustee companies) company falls within the period between 1 June 2017 and 31 December 2023 (both dates inclusive) — 12%; or
where the effective date of the company’s approval or the effective date of the extension of its approval as a financial sector incentive (trustee companies) company is on or after 1 January 2024 — 13.5%.
Subregulation 2
In this regulation, “holding company”, in relation to a trust, means a company —
which is set up to hold the assets of the trust;
whose operations consist solely of trading in or making investments for the purpose of the trust; and
whose shares are all held by the trustees of the trust, or by their nominee.