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Exemption from tax under section 13U(1)(d) of Act

Income Tax (Exemption of Income Arising from Funds Managed in Singapore by Fund Manager) Regulations 2010

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—(1) For the purpose of section 13U(1)(d) of the Act, subject to the conditions in paragraph (2) and regulations 4, 5 and 6, the following income is exempt from tax for any year of assessment:(a)in the case of a company which is the approved master fund of an approved master 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 of an approved master 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 of an approved master 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 fund-SPV structure, any specified income derived by the approved 1st tier SPV from funds of the approved master 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 fund-SPV structure, any specified income derived by the approved 2nd tier SPV from funds of the approved master fund of that structure managed in Singapore by a fund manager in respect of designated investments;(f)in the case of an approved eligible SPV of an approved master 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;(g)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 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;(h)in the case of a trustee of a trust fund, where the trust fund is an approved eligible SPV of an approved master 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;(i)in the case of a taxable entity of an approved eligible SPV of an approved master 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.(2) The conditions mentioned in paragraph (1) are —(a)throughout the basis period for that year of assessment, the funds of the approved master fund are managed in Singapore by a fund manager;(b)the approved master fund —(i)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;(ii)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(iii)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;(c)at the time of the application for approval of the master fund-SPV structure, the aggregate amount of —(i)the funds of the master fund and all SPVs of that structure managed in Singapore by the fund manager; or(ii)if the approved master 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 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 the master fund and of all SPVs of that structure (regardless of whether the SPVs are carrying on any income-deriving activity at that time); andBis $50 million;where Ais the total number of entities in that structure which are carrying on one or more income-deriving activities at that time; andBis $50 million;(d)for that year of assessment, no part of the income of the approved master fund or any approved SPV of the approved master fund-SPV structure (other than any income derived before the approved master fund-SPV structure was approved as such) —(i)is exempt from tax under section 13C, 13D, 13F, 13G, 13L, 13M, 13N, 13O, 13T or 13V of the Act;(ii)is subject to a concessionary rate of tax under section 43D, 43E or 43J of the Act; or(iii)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(e)[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 fund-SPV structure under section 13U of the Act.

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