Singapore legislation
Regulation 4
Regulation 4
Concessionary tax rate for income relating to leasing containers and related foreign exchange and risk management activities
Subregulation 1
Tax at the rate specified for any income of an ACIE under section 43ZA(1) of the Act, is levied and must be paid on the income described in sub‑paragraph (2) of the ACIE that is received in Singapore during the period of the ACIE’s approval.
Subregulation 2
The income to which sub‑paragraph (1) applies is dividends of an approved company of the ACIE, or partnership profits of an approved partnership of the ACIE, that are paid out of income derived by the approved company or approved partnership, during the company’s or partnership’s period of approval, from any of the following activities:
the leasing during the qualifying period of any container owned by the approved company or approved partnership, that is acquired before or during the period of the company’s or partnership’s approval and is used for the international transportation of goods;
foreign exchange and risk management activities that are carried out in connection with and incidental to the activity mentioned in sub‑paragraph (a).
Subregulation 3
Sub‑paragraph (1) also applies to the income of the ACIE described in sub‑paragraph (2) that is —
received in Singapore after the date the ACIE’s approval has expired or been withdrawn; or
paid out of income derived by an approved company or approved partnership of the ACIE from any of the activities mentioned in sub‑paragraph (2) after the date the approval of the approved company or approved partnership has expired or been withdrawn,if the ACIE has fulfilled all of the conditions specified under section 43ZA(4) of the Act for its approval by the date of expiry or before the date of the withdrawal of the approval.
Subregulation 4
Sub‑paragraph (1) does not apply to income that is paid out of income derived —
at any time before 24 February 2015 from the leasing of a container under a finance lease that is treated as a sale under regulations made under section 10D(1) of the Act; or
from any activity carried out by a permanent establishment of the approved company or approved partnership in Singapore.
Subregulation 5
In sub‑paragraph (1), the qualifying period of a container is the period specified under section 43ZA(5) of the Act during which income from the leasing of the container, or the class of containers to which the container belongs, is subject to the concessionary tax rate under section 43ZA(1) of the Act.