Regulation 3B

in the case of a company which is the approved master fund or an approved feeder fund of an approved master-feeder fund-SPV structure, any specified income derived by the company from funds of the company managed in Singapore by a fund manager in respect of designated investments; (b)in the case of a trustee of a trust fund which is the approved master fund or an approved feeder fund of an approved master-feeder fund-SPV structure, any specified income derived by the trustee from funds of the trust fund managed in Singapore by a fund manager in respect of designated investments; (c)in the case of a partner of a limited partnership which is the approved master fund or an approved feeder fund of an approved master-feeder fund-SPV structure, the share to which the partner is entitled in any specified income derived by the partnership from funds of the partnership managed in Singapore by a fund manager in respect of designated investments; (d)in the case of an approved 1st tier SPV of an approved master-feeder fund-SPV structure, any specified income derived by the approved 1st tier SPV from funds of the approved master fund or an approved feeder fund of that structure managed in Singapore by a fund manager in respect of designated investments; (e)in the case of an approved 2nd tier SPV of an approved master-feeder fund-SPV structure, any specified income derived by the approved 2nd tier SPV from funds of the approved master fund or an approved feeder fund of that structure managed in Singapore by a fund manager in respect of designated investments;

in the case of an approved eligible SPV of an approved master-feeder fund-SPV structure, where the approved eligible SPV is not one mentioned in sub-paragraphs (g), (h) and (i), any specified income derived by the approved eligible SPV from funds of the approved eligible SPV managed in Singapore by a fund manager in respect of designated investments;

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

in the case of a trustee of a trust fund, where the trust fund is an approved eligible SPV of an approved master-feeder fund-SPV structure, any specified income derived by the trustee from funds of the trust fund managed in Singapore by a fund manager in respect of designated investments;

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

in the case of a person (other than a company) that is an approved feeder fund of an approved master-feeder fund-SPV structure — any specified income derived by the person from funds of the person 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 an approved feeder fund of an approved master-feeder fund-SPV structure — the share to which the partner is entitled in any specified income derived by the partnership from funds of the partnership managed in Singapore by a fund manager in respect of designated investments;

in the case of a taxable entity in relation to an approved feeder fund of an approved master-feeder fund-SPV structure, where the approved feeder fund is not a legal entity — any specified income derived by the taxable entity from funds of the approved feeder fund 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 approved master fund or approved feeder fund, as the case may be, are managed in Singapore by a fund manager;

the approved master fund —

if it is a company, must be incorporated in Singapore and must be resident in Singapore throughout the basis period for that year of assessment;

if it is a trust fund, must be constituted in Singapore and the trustee of which must be resident in Singapore throughout the basis period for that year of assessment; or

if it is a limited partnership, must be registered in Singapore and all the partners of which (including all limited partners) must be resident in Singapore throughout the basis period for that year of assessment;

at the time of the application for approval of the master-feeder fund-SPV structure, the aggregate amount of —

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

if the master-feeder fund-SPV 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, all feeder funds and all SPVs 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 of the number of each of the following: (i)the master fund; (ii)the feeder funds of that structure which are carrying on one or more income-deriving activities at that time; (iii)all SPVs of that structure (regardless of whether the SPVs are carrying on any income-deriving activity at the time); andBis $50 million;

for that year of assessment, no part of the income of the approved master fund, any approved feeder fund or any approved SPV of the approved master-feeder fund-SPV structure (other than any income derived before the approved master-feeder fund-SPV 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 subject to any 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](f)conditions specified in the letter of approval issued by the Monetary Authority of Singapore approving the master-feeder fund-SPV structure under section 13U of the Act.