Regulation 3A

in the case of a company or trustee of a trust fund where the company or trust fund is the approved master fund or an approved feeder fund of an approved master-feeder fund structure, any specified income derived by the company or trustee arising from funds of the master fund or the feeder fund that are managed in Singapore by a fund manager in respect of designated investments; and

in the case of a partner of a limited partnership where the partnership is the approved master fund or an approved feeder fund of an approved master-feeder fund structure, the share to which the partner of the partnership is entitled in any specified income derived by the partnership arising from funds of the master fund or the feeder fund that are managed in Singapore by a fund manager in respect of designated investments.

in the case of a person (other than a company) that is the approved master fund or an approved feeder fund of an approved master-feeder fund structure — any specified income derived by the person from funds of the master fund or the feeder fund that are managed in Singapore by a fund manager in respect of designated investments;

in the case of a partner of a partnership (excluding a limited partnership but including a limited liability partnership), where the partnership is the approved master fund or an approved feeder fund of an approved master-feeder fund structure — the share to which the partner of the partnership is entitled in any specified income derived by the partnership from funds of the master fund or the feeder fund that are managed in Singapore by a fund manager in respect of designated investments;

in the case of a taxable entity in relation to the approved master fund or an approved feeder fund of an approved master-feeder fund structure, where the master fund or feeder fund is not a legal entity — any specified income derived by the taxable entity from funds of the master fund or the feeder fund that are managed in Singapore by a fund manager in respect of designated investments.

throughout the basis period for that year of assessment, the funds of the following are managed in Singapore by a fund manager:

in the case of sub-paragraph (a) of paragraph (1) — the company or trust fund mentioned in that sub-paragraph;

in the case of sub-paragraph (b) of paragraph (1) — the limited partnership mentioned in that sub-paragraph;

in the case of sub-paragraph (a) of paragraph (1A) — the person mentioned in that sub-paragraph;

in the case of sub-paragraph (b) of paragraph (1A) — the partnership mentioned in that sub-paragraph;

in the case of sub-paragraph (c) of paragraph (1A) — the master fund or feeder fund mentioned in that sub-paragraph;

at the time of the application for approval of the master-feeder fund structure —

where no feeder fund carries on any income-deriving activity at that time, the aggregate amount of —

the funds of the master fund and all feeder funds of that structure managed in Singapore by the fund manager; or

if the master-feeder fund structure is a private equity fund, a real estate fund, an infrastructure fund, a debt and credit fund or a fund whose primary purpose is to invest in private equity funds, the committed funds of the master fund and all feeder funds of that structure managed in Singapore by the fund manager,is at least $50 million; or

where any feeder fund carries on any income-deriving activity at that time, the aggregate amount of —

the funds of the master fund and all feeder funds of that structure managed in Singapore by the fund manager; or

if the master-feeder fund structure is a private equity fund, a real estate fund, an infrastructure fund, a debt and credit fund or a fund whose primary purpose is to invest in private equity funds, the committed funds of the master fund and all feeder funds of that structure managed in Singapore by the fund manager,is at least an amount which is computed in accordance with the following formula:where Ais the aggregate number of the master fund and feeder funds in that structure which are carrying on one or more income-deriving activities at that time; andBis $50 million;

for that year of assessment, no part of the income of the approved master fund or any approved feeder fund of the approved master-feeder fund structure (other than any income derived before the approved master-feeder fund structure was approved as such) —

is exempt from tax under section 13C, 13D, 13F, 13G, 13L, 13M, 13N, 13O, 13T or 13V of the Act;

is subject to a concessionary rate of tax under section 43D, 43E or 43J of the Act; or

is entitled to any tax relief or concessionary rate of tax under Part 3 or 4 of the Economic Expansion Incentives (Relief from Income Tax) Act 1967; and

[Deleted by S 56/2025 wef 20/01/2025](e)conditions specified in the letter of approval issued by the Monetary Authority of Singapore approving the master‑feeder fund structure under section 13U of the Act.