Regulation 2

the provision of services by a trustee company in its capacity as trustee of a foreign trust, including services provided as manager or administrator of an eligible holding company in relation to that foreign trust; or

the provision of services by a trustee company to a trustee of a foreign trust under a contract for services with that trustee, such services being all or any of the following:

the establishing of a foreign trust or an eligible holding company;

the administration or management of a foreign trust or an eligible holding company;“compensatory payment” has the same meaning as in section 10H(12) of the Act;“designated investments” has the same meaning as in the Income Tax (Exemption of Income of Prescribed Persons Arising from Funds Managed by Fund Manager in Singapore) Regulations 2010 (G.N. No. S 6/2010), with references to “prescribed person” therein modified to refer to the eligible holding company or foreign trust referred to in regulation 3, as the case may be;“eligible holding company” means a company —

which is incorporated outside Singapore;

which is set up to hold assets of a foreign trust administered by a trustee company in Singapore;

whose operations consist solely of trading or making investments for the purpose of the foreign trust;

which does not claim any relief under any arrangement made under section 49 of the Act or any tax credit under section 50A of the Act; and

all the shares of which are held by the trustees of the foreign trust, or by their nominee;“foreign company” means a company which is neither incorporated nor resident in Singapore and —

where the company has not more than 50 shareholders, all of its issued shares are beneficially owned, directly or indirectly, by persons who are neither citizens of Singapore nor resident in Singapore; and

where the company has more than 50 shareholders, not less than 95% of the total number of issued shares of the company are beneficially owned, directly or indirectly, by persons who are neither citizens of Singapore nor resident in Singapore;“nominee” means any person who acts as a nominee or custodian in relation to shares of an eligible holding company for and on behalf of the trustees of a foreign trust;“qualifying debt securities” has the same meaning as in section 13(16) of the Act;“securities lending or repurchase arrangement” has the same meaning as in section 10H(12) of the Act;“specified income” means —

[Deleted by S 486/2021 wef 01/07/2021](b)[Deleted by S 486/2021 wef 01/07/2021](c)in relation to income derived between 21 February 2014 and 8 March 2020 (both dates inclusive), income specified in Part C of the Schedule; and

in relation to income derived on or after 9 March 2020, income specified in Part D of the Schedule;“unit trust” means any trust established for the purpose, or having the effect, of providing facilities for the participation by persons as beneficiaries under a trust, in profits or income arising from the acquisition, holding, management or disposal of securities or any other property.