Singapore legislation

Regulation 8

of Income Tax (Exemption and Concessionary Tax Rate for Income from Life Reinsurance Business) Regulations 2017

Regulation 8

Apportionment of expenses, allowances and donations

Subregulation 1

For the purpose of determining the income mentioned in regulation 6(2), all of the following for which a deduction is allowable to an approved insurer under the Act, are to be apportioned between the onshore life reinsurance business in Singapore and offshore life reinsurance business in Singapore of the insurer, and the other life businesses of the insurer:

(a)

any item of expenditure not directly attributable to the onshore life reinsurance business in Singapore and offshore life reinsurance business in Singapore of the insurer;

(b)

capital allowances;

(c)

donations.

Subregulation 2

For the purposes of paragraph (1), the portion of expenditure, capital allowances and donations to be apportioned to the onshore life reinsurance business in Singapore and offshore life reinsurance business in Singapore of the approved insurer is that ascertained using the fraction , where “Pil”, “Pilr”, “Pol” and “Polr” have the same meanings as in regulation 6(3).

Subregulation 3

For the purpose of determining the income mentioned in regulation 7(3), all of the following for which a deduction is allowable to an approved captive insurer under the Act, are to be apportioned between the captive life business in Singapore (excluding specified business) of the insurer and the other life businesses of the insurer:

(a)

any item of expenditure not directly attributable to the captive life business in Singapore (excluding specified business) of the insurer;

(b)

capital allowances;

(c)

donations.

Subregulation 4

For the purposes of paragraph (3), the portion of expenditure, capital allowances and donations to be apportioned to the captive life business in Singapore (excluding specified business) of the approved captive insurer is that ascertained using the fraction , where —

(a)

“Pil” and “Pol” have the same meanings as in regulation 6(3), with each reference to the approved insurer substituted with the reference to the approved captive insurer; and

(b)

“Pilc” and “Polc” have the same meanings as in regulation 7(4).

Subregulation 5

The Comptroller may apply any alternative method of apportionment in place of any of the prescribed fractions in paragraph (2) or (4) if the Comptroller is satisfied that the alternative method is reasonable in the circumstances of the business of the insurer mentioned in that paragraph.