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Exemption from tax of qualifying amount paid by approved master fund, etc., in section 13U of Act in relation to approved master-feeder fund-SPV structure

Income Tax (Exemption of Interest and Other Payments for Economic and Technological Development) (No. 2) Notification 2012

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—(1) There is exempt from tax, in relation to an approved master-feeder fund-SPV structure, any qualifying amount liable to be paid by a person in the first column of the following table, on or after the date specified opposite that person in the second column of that table, to —(a)a person who is neither resident in Singapore nor has a permanent establishment in Singapore; or(b)a person who is not resident in Singapore and who carries on any operation in Singapore through a permanent establishment in Singapore, where the qualifying amount is not liable to be paid in connection with any loan or indebtedness or with any arrangement, management, guarantee, or service relating to any loan or indebtedness undertaken or performed through that operation,during a basis period described in sub-paragraph (2):First columnSecond columnPersonSpecified date1.A company incorporated in Singapore, a trustee of a trust fund (being a trust fund constituted in Singapore) or a partner of a limited partnership registered in Singapore, where the company, trust fund or limited partnership (as the case may be) is the approved master fund of the structure1 April 20152.A company, a trustee of a trust fund or a partner of a limited partnership, where the company, trust fund or limited partnership (as the case may be) is an approved feeder fund of the structure1 April 20153.A person (not being a company, an individual or a Hindu joint family) that is an approved feeder fund of the structure20 February 20184.A partner of a partnership (including a limited liability partnership but excluding a limited partnership), where the partnership is an approved feeder fund of the structure20 February 20185.A taxable entity in relation to an approved feeder fund of the structure, where the feeder fund is not a legal entity20 February 20186.An approved 1st tier SPV of the structure, that is a company1 April 20157.An approved 2nd tier SPV of the structure, that is a company1 April 20158.An approved eligible SPV of the structure, that is a person (not being a company, an individual or a Hindu joint family)19 February 20199.An approved eligible SPV of the structure, where the eligible SPV is not one mentioned in items 8, 10, 11 and 1219 February 201910.A partner of an approved eligible SPV of the structure, where the eligible SPV is a partnership (including a limited partnership and a limited liability partnership)19 February 201911.The trustee of an approved eligible SPV of the structure, where the eligible SPV is a trust fund19 February 201912.The taxable entity of an approved eligible SPV of the structure, where the eligible SPV is not a legal entity19 February 2019(2) The basis period is either of the following:(a)a basis period where all of the conditions in regulation 3B(2)(a), (b), (d), (e) and (f) of the Income Tax (Exemption of Income Arising from Funds Managed in Singapore by Fund Manager) Regulations 2010 (whichever is applicable) are satisfied throughout that basis period in relation to the master fund and master-feeder fund-SPV structure, the feeder fund and master-feeder fund-SPV structure, or the SPV and master-feeder fund-SPV structure (as the case may be), being the first time that all of those conditions are satisfied in relation to the master fund and master-feeder fund-SPV structure, the feeder fund and master-feeder fund-SPV structure, or the SPV and master-feeder fund-SPV structure, as the case may be; and(b)a basis period immediately following another basis period where all of those conditions (whichever is applicable) are satisfied throughout that other basis period in relation to the master fund and master-feeder fund-SPV structure, the feeder fund and master-feeder fund-SPV structure, or the SPV and master-feeder fund-SPV structure, as the case may be.(3) For the purposes of sub-paragraph (2) —(a)the reference in regulation 3B(2)(a) and (b)(i), (ii) and (iii) of the Income Tax (Exemption of Income Arising from Funds Managed in Singapore by Fund Manager) Regulations 2010 to the basis period for the year of assessment for which income is exempt from tax under those Regulations is to the basis period referred to in sub-paragraph (2)(a) or (b), as the case may be; and(b)the reference in regulation 3B(2)(d) of the Income Tax (Exemption of Income Arising from Funds Managed in Singapore by Fund Manager) Regulations 2010 to the year of assessment for which income is exempt from tax under those Regulations is to the year of assessment to which the basis period referred to in sub-paragraph (2)(a) or (b), as the case may be, relates.(4) In this paragraph, “1st tier SPV”, “2nd tier SPV”, “approved”, “eligible SPV”, “feeder fund”, “master-feeder fund-SPV structure”, “master fund”, “SPV”, “taxable entity” and “trust fund” have the meanings given by section 13U(5) of the Act.

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