Singapore legislation
Regulation 3
Regulation 3
Exemption
Subregulation 1
Subject to sub‑paragraphs (2), (3) and (4), where a qualifying payment is made by a bank in Singapore to a bank outside Singapore, the qualifying payment is exempt from tax if the qualifying payment —
is liable to be made at any time during the period from 1 April 2021 to 31 December 2031 (both dates inclusive) under —
a contract which took effect before 1 April 2021;
a contract which was extended or renewed, where the extension or renewal took effect before 1 April 2021; or
a debt security which was issued before 1 April 2021; (b)is liable to be made under a contract which takes effect on a date which falls within the period from 1 April 2021 to 31 December 2031 (both dates inclusive);
is liable to be made —
under a contract which is extended or renewed, where the extension or renewal takes effect on a date which falls within the period from 1 April 2021 to 31 December 2031 (both dates inclusive); and
on or after the date on which the extension or renewal takes effect; (ca)is liable to be made —
under a contract which is varied, where the variation takes effect on a date which falls within the period from 4 November 2022 to 31 December 2031 (both dates inclusive); and
on or after the date on which the variation takes effect; or
is liable to be made under a debt security which is issued on a date which falls within the period from 1 April 2021 to 31 December 2031 (both dates inclusive).
Subregulation 2
The exemption in sub‑paragraph (1) only applies —
if the bank outside Singapore is not resident in Singapore and does not have a permanent establishment in Singapore; or (b)if the bank outside Singapore is not resident in Singapore and carries on an operation in Singapore through a permanent establishment in Singapore, and —
the contract under which the qualifying payment is made is not entered into through that operation; or
the debt security under which the qualifying payment is made is not acquired by the bank outside Singapore through that operation.
Subregulation 3
The exemption in sub‑paragraph (1) does not apply to any qualifying payment made by a bank in Singapore in connection with an arrangement mentioned in section 33(1) of the Act.
Subregulation 4
The exemption in sub-paragraph (1) does not apply to any qualifying payment liable to be made —
under a contract mentioned in sub-paragraph (1)(b), (c) or (ca), that is varied with effect from a date on or after 1 January 2032; and
on or after the date on which the variation takes effect.