Income Tax (Concessionary Rate of Tax for Financial Sector Incentive Companies) Regulations 2005

at the time of their issue by the company; or

in the case of derivatives of a buy-sell nature for funding purpose, at the time of their buy-sell transaction.

a financial sector incentive (bond market) company;

a financial sector incentive (credit facilities syndication) company;

a financial sector incentive (derivatives market) company;

a financial sector incentive (equity market) company;

a financial sector incentive (fund management) company;

a financial sector incentive (headquarter services) company;

a financial sector incentive (standard tier) company;

a financial sector incentive (project finance) company;

a financial sector incentive (debt capital market) company;

a financial sector incentive (Islamic finance) company;

a financial sector incentive (derivatives market) (exchange-traded commodity derivatives) company;

a financial sector incentive (derivatives market) (financial) company;

a financial sector incentive (derivatives market) (financial, over-the-counter and exchange-traded commodity derivatives) company;

a financial sector incentive (derivatives market) (over-the-counter commodity derivatives) company; (o)a financial sector incentive (derivatives market) (over-the-counter and exchange-traded commodity derivatives) company;

a financial sector incentive (capital market) company;

a financial sector incentive (trustee companies) company.

is not licensed or approved by the Monetary Authority of Singapore, or is exempted from such licensing or approval, under any Act; and

provides treasury, investment or financial services in Singapore for any of its offices or its associated companies.

the company is exempted from holding a capital markets services licence for fund management under the Securities and Futures Act 2001; and (b)the company provides treasury, investment or financial services in Singapore for any of its offices or its associated companies.

the company provides treasury, investment or financial services in Singapore for any of its offices or its associated companies; and

the company —

directly or indirectly wholly owns, or is directly or indirectly wholly-owned by, another company in Singapore that is licensed or approved by the Monetary Authority of Singapore under any written law administered by the Monetary Authority of Singapore; or

directly or indirectly wholly owns, or is directly or indirectly wholly-owned by, another company outside Singapore that is licensed or approved under any written law administered by the financial supervisory authority of the other company.

for such period not exceeding 10 years as he may specify; and

subject to such terms and conditions as he may impose.

in the case of a financial sector incentive (headquarter services) company, for such further period not exceeding 10 years; and

in any other case, for such further period not exceeding 5 years,at any one time as he may specify, subject to such terms and conditions as he may impose.

any of the following on or after 1st January 2014:

a financial sector incentive (bond market) company;

[Deleted by S 212/2016 wef 01/01/2014](iii)a financial sector incentive (debt capital market) company;

a financial sector incentive (derivatives market) (exchange-traded commodity derivatives) company;

a financial sector incentive (derivatives market) (financial) company;

a financial sector incentive (derivatives market) (financial, over-the-counter and exchange-traded commodity derivatives) company;

a financial sector incentive (derivatives market) (over-the-counter commodity derivatives) company;

a financial sector incentive (derivatives market) (over-the-counter and exchange-traded commodity derivatives) company;

a financial sector incentive (equity market) company; (x)[Deleted by S 212/2016 wef 01/01/2014](xi)[Deleted by S 212/2016 wef 01/01/2014](xii)[Deleted by S 212/2016 wef 01/01/2014](b)a financial sector incentive (project finance) company on or after 1st January 2012;

a financial sector incentive (Islamic finance) company on or after 1st April 2013;

a financial sector incentive (derivatives market) company between 27 February 2009 and 31 December 2013 (both dates inclusive) and on or after 1 June 2017; or

any of the following on or after 1 June 2017:

a financial sector incentive (capital market) company;

a financial sector incentive (credit facilities syndication) company;

a financial sector incentive (fund management) company;

a financial sector incentive (headquarter services) company; (v)a financial sector incentive (standard tier) company;

a financial sector incentive (trustee companies) company.

where the financial sector incentive (standard tier) company is a bank that holds a licence under section 7 or 79 of the Banking Act 1970, or a merchant bank approved under section 28 of the Monetary Authority of Singapore Act 1970 on or before 31 December 2010 —

granting loans, other than by way of bonds or debentures, in any foreign currency, the repayment of which is not in Singapore currency;

trading in secondary loans in any foreign currency, the repayment of which is not in Singapore currency;

transactions in any foreign currency with any bank or branch office in respect of any of the following:

placement of funds;

bankers’ acceptances on bills relating to trade transactions;

bills relating to trade transactions;

negotiable certificates of deposit;

opening, advising or confirming of letters of credit denominated in any foreign currency relating to trade transactions;

financing or re-financing of trade transactions with or without letters of credit denominated in any foreign currency;

providing guarantees, performance bonds, standby letters of credit and services relating to remittances denominated in foreign currencies; and

providing services to any non-resident holder of a credit or charge card, in connection with the use of the card, where —

the billing for the transactions for which the card is used is denominated in any foreign currency;

the card is used outside Singapore for the purposes of making payments to a person outside Singapore who is neither resident in Singapore nor a permanent establishment in Singapore; and

the payments for such services to the financial sector incentive (standard tier) company are not borne, directly or indirectly, by a person resident in Singapore or a permanent establishment in Singapore, except in respect of any business carried on outside Singapore through a permanent establishment outside Singapore;

trading in any debt securities;

arranging, managing, underwriting, selling or investing in qualifying debt securities;

arranging, managing, underwriting, selling, investing in or providing services (including services as a broker, nominee or custodian) in respect of foreign debt securities;

granting loans of foreign debt securities under securities lending arrangements in writing;

arranging, managing, underwriting, selling or providing other services (including services as a broker, nominee or custodian) in respect of foreign equity securities;

granting loans of foreign equity securities under securities lending arrangements in writing;

foreign exchange transactions;

providing services as an intermediary in connection with transactions relating to derivatives;

trading in derivatives;

transactions in gold bullion, silver bullion or platinum bullion;

managing the funds of a foreign investor for the purpose of any designated investment, or providing investment advisory services to a foreign investor in respect of designated investments, where the payments for the services are not borne, directly or indirectly, by a person resident in Singapore or by a permanent establishment in Singapore;

arranging, on behalf of a foreign investor, any loan of designated securities under a securities lending arrangement in writing to another financial sector incentive (standard tier) company or a financial sector incentive (fund management) company, where the payments for the services are not borne, directly or indirectly, by a person resident in Singapore or by a permanent establishment in Singapore;

providing advisory services relating to financial matters (other than investment advisory services in respect of fund management);

providing trustee or custodian services in its capacity as a trustee of a relevant foreign trust, where the payments for the services are not borne, directly or indirectly, by a person resident in Singapore or by a permanent establishment in Singapore;

providing trustee or custodian services for or on behalf of any unit trust the trust fund of which is a foreign investor and the funds of which are invested in designated investments, where the payments for the trustee or custodian services are not borne, directly or indirectly, by a person resident in Singapore or by a permanent establishment in Singapore;

providing custodian services for or on behalf of any foreign mutual fund corporation, the funds of which are invested in designated investments, where the payments for the custodian services are not borne, directly or indirectly, by a person resident in Singapore or by a permanent establishment in Singapore;

providing trustee services in respect of foreign bond or loan stock issues, including services for monitoring loan covenants and administering loan repayments, where the payments for the services are not borne, directly or indirectly, by a person resident in Singapore or by a permanent establishment in Singapore;

providing trust management or administration services to any trustee of a relevant foreign trust, where the payments for the services are not borne, directly or indirectly, by a person resident in Singapore or by a permanent establishment in Singapore;

trading, on or after 27th February 2004, in secondary loans in any foreign currency, the repayment of which is not in Singapore currency.

the reference in section 43H(2) of the Act to the application of section 43H(1)(a), (aa), (ab) or (ac) of the Act; and

a reference in regulation 7 of the Income Tax (Concessionary Rate of Tax or Exemption for Income Derived from Debt Securities) Regulations to the application of the concessionary rate of tax referred to in regulation 3(aa), (ab), (ac) or (ad) of those Regulations,shall each be read as a reference to the application of the rate of tax under paragraph (1).

any income which is derived from the granting of loans referred to in paragraphs (1)(g) and (2A)(a), and which comprises Singapore dividends from which tax is deducted or deductible under section 44 of the Act, shall be excluded;

1st September 2007; or

where an option has been exercised under regulation 8 of the Income Tax (Exemption of Income of Approved Companies Arising from Funds Managed by Fund Manager in Singapore) Regulations 2010 (G.N. No. S 8/2010), the date which the Income Tax (Exemption of Income of Approved Companies from Funds Managed by Fund Manager) Regulations 2007 (G.N. No. S 628/2007) cease to apply; and

the qualifying base shall be deducted from the income derived or loss incurred before 1st January 2011 from the activities specified in paragraphs (1), (2A), (2B), (2C), (2D), (2E), (2F) and (2G).

granting any loan of any debt and equity securities under a securities lending or repurchase arrangement, other than a loan of —

foreign debt securities;

foreign equity securities; or

stocks and shares of any company resident in Singapore which are not listed on any stock exchange in Singapore or elsewhere; or

arranging any loan of any debt and equity securities under a securities lending or repurchase arrangement, other than —

arranging a loan of stocks and shares of any company resident in Singapore which are not listed on any stock exchange in Singapore or elsewhere; or

arranging, on behalf of a foreign investor, a loan of designated securities to another financial sector incentive (standard tier) company or a financial sector incentive (fund management) company, where payment for the arrangement of the loan is not borne, directly or indirectly, by a person resident in Singapore or by a permanent establishment in Singapore.

managing the funds of the second-mentioned company for the purpose of any designated investment;

providing investment advisory services to the second-mentioned company in respect of designated investments; or

arranging, on behalf of the second-mentioned company, any loan of designated securities under a securities lending arrangement in writing to another financial sector incentive (standard tier) company or a financial sector incentive (fund management) company,provided that —

the second-mentioned company was incorporated at any time between 18th February 2005 and 17th February 2010 (both dates inclusive);

the date of incorporation of the second-mentioned company is stated in its charter, statute or memorandum and articles or other instrument constituting it or defining its constitution;

at the date of incorporation of the second-mentioned company, the first-mentioned company was already an approved start-up company;

the second-mentioned company has been managed by the first-mentioned company since the date of incorporation of the second-mentioned company; and

the second-mentioned company was not incorporated with the avoidance or reduction of tax chargeable under the Act as its main purpose or one of its main purposes.

managing the funds of the trust fund for the purpose of any designated investment;

providing investment advisory services to the trust fund in respect of designated investments; or

arranging, on behalf of the trust fund, any loan of designated securities under a securities lending arrangement in writing to another financial sector incentive (standard tier) company or a financial sector incentive (fund management) company,provided that —

the trust fund was constituted at any time between 18th February 2005 and 17th February 2010 (both dates inclusive);

the date of constitution of the trust fund is stated in the relevant trust instrument;

at the date of constitution of the trust fund, the company was already an approved start-up company;

the trust fund has been managed by that company since the constitution of that trust fund; and

the trust fund was not constituted with the avoidance or reduction of tax chargeable under the Act as its main purpose or one of its main purposes.

managing the funds of an approved company for the purpose of any designated investments;

providing investment advisory services to an approved company in respect of any designated investments.

managing the funds of a prescribed person for the purpose of any designated investments, provided the prescribed person has no non-qualifying investor as at the last day of the basis period of the prescribed person for the relevant year of assessment;

managing the funds of an approved company for the purpose of any designated investments, provided the approved company has no non-qualifying investor as at the last day of the basis period of the approved company for the relevant year of assessment;

subject to regulation 7, managing the funds of a trustee of a prescribed trust fund for the purpose of any designated investments, where the payments for those services are not borne, directly or indirectly, by a person resident in Singapore or by a permanent establishment in Singapore (other than a fund manager of, or a trustee in its capacity as the trustee of the prescribed trust fund);

providing investment advisory services to a prescribed person in respect of any designated investments (including through a fund manager outside Singapore), provided the prescribed person has no non-qualifying investor as at the last day of the basis period of the prescribed person for the relevant year of assessment;

providing investment advisory services to an approved company in respect of any designated investments (including through a fund manager outside Singapore), provided the approved company has no non-qualifying investor as at the last day of the basis period of the approved company for the relevant year of assessment;

subject to regulation 7, providing investment advisory services to a trustee of a prescribed trust fund in respect of any designated investments, where the payments for those services are not borne, directly or indirectly, by a person resident in Singapore or by a permanent establishment in Singapore (other than a fund manager of, or a trustee in its capacity as the trustee of the prescribed trust fund);

subject to regulation 7, arranging on behalf of a trustee of a prescribed trust fund, any loan of designated securities under a securities lending arrangement in writing to another financial sector incentive (standard tier) company or a financial sector incentive (fund management) company, where the payments for the services are not borne, directly or indirectly, by a person resident in Singapore or by a permanent establishment in Singapore;

subject to regulation 7, providing investment advisory services to a trustee of a prescribed trust fund through a fund manager outside Singapore in respect of designated investments, where the payments for those services are not borne, directly or indirectly, by a person resident in Singapore or by a permanent establishment in Singapore.

managing the funds of an approved person for the purpose of any designated investments;

providing investment advisory services to an approved person in respect of any designated investments (including through a fund manager outside Singapore).

managing the funds of the approved master fund or an approved feeder fund of an approved master-feeder fund structure, for the purpose of any designated investments;

providing investment advisory services to the approved master fund or an approved feeder fund of an approved master‑feeder fund structure in respect of any designated investments (including through a fund manager outside Singapore).

income from any of the activities specified in Part 1 of the Fourth Schedule; and

interest from any deposit held by the company as a corporate futures member as a margin for any transaction in relation to any activity referred to in sub-paragraph (i), (k) or (l) of Part 1 of the Fourth Schedule.

income from any of the activities specified in the Fifth Schedule; and

interest from any deposit held by the company as a corporate futures member as a margin for any transaction in relation to any activity mentioned in sub‑paragraph (j), (l) or (m) of the Fifth Schedule.

income from any of the activities specified in the Sixth Schedule; and (b)interest from any deposit held by the company as a corporate futures member as a margin for any transaction in relation to any activity mentioned in paragraph 1(e), (g) or (h) of the Sixth Schedule.

any interest derived from any qualifying debt securities issued during the period from 10th May 1999 to 31st December 2023 (both dates inclusive);

any discount from any qualifying debt securities issued during the period from 17th February 2006 to 31st December 2023 (both dates inclusive); (c)any amount payable from any Islamic debt securities which are qualifying debt securities, and issued during the period from 1st January 2005 to 31st December 2023 (both dates inclusive); and

any prepayment fee, redemption premium or break cost from qualifying debt securities issued during the period from 15th February 2007 to 31st December 2023 (both dates inclusive),where 50% or more of those securities which are outstanding at any time during the life of the issue is beneficially held or funded, directly or indirectly, by related parties of the issuer of those securities and where such income is derived by —

any financial sector incentive (standard tier) company which is a related party of the issuer of those securities; or (ii)any financial sector incentive (standard tier) company where the funds used by such company to acquire those securities are obtained, directly or indirectly, from any related party of the issuer of those securities.

a return on those securities within such period as the Monetary Authority of Singapore may specify; and (b)such other particulars in connection with those securities as the Monetary Authority of Singapore may require.

trustee or custodian services in the company’s capacity as a trustee of a relevant foreign trust, or as a trustee of a philanthropic purpose trust in respect of a foreign account;

trustee or custodian services for or on behalf of any unit trust —

which is also a trust fund that is a foreign investor; and

the funds of which are invested in designated investments;

trustee or custodian services in respect of foreign bond or loan stock issues, including services for monitoring loan covenants and administering loan repayments;

custodian services for or on behalf of any foreign mutual fund corporation, where the funds of the foreign mutual fund corporation are invested in designated investments;

trust management or administration services provided to a trustee of a relevant foreign trust, to any eligible holding company of a relevant foreign trust, or to a trustee of a philanthropic purpose trust in respect of a foreign account;

trustee services in respect of the issue of units of —

a foreign collective investment scheme; or

a foreign business trust,where the proceeds of the issue of the units are used outside Singapore;

custodian services in respect of —

any qualifying debt securities;

any foreign debt securities;

any foreign equity securities;

any units in a foreign collective investment scheme; or

any units in a foreign business trust.

general management and administration;

business planning and co-ordination;

procurement of raw materials and components for use in the business of the approved office or approved person;

technical support services;

marketing control and sales promotion planning;

training and personnel management;

corporate finance advisory services;

economic or investment research and analysis;

credit control and administration;

research and development work carried out in Singapore on behalf of the approved office;

arranging credit facilities for the approved office in foreign currencies where the funds for providing the facilities are obtained from —

financial institutions in Singapore; or

the accumulated profits of other approved offices;

providing guarantees, performance bonds, standby letters of credit and services relating to remittances where —

in the case of a guarantee, performance bond or standby letter of credit, the party in whose favour the facility is issued is —

a bank that holds a licence under section 7 or 79 of the Banking Act 1970, or a merchant bank approved under section 28 of the Monetary Authority of Singapore Act 1970 on or before 30 June 2021, which is a financial sector incentive company;

a person who is neither a resident of nor a permanent establishment in Singapore; or (C)a permanent establishment outside Singapore of a person resident in Singapore in respect of any business carried on outside Singapore through that permanent establishment; and

in the case of services relating to remittances, the person to whom the remittances are made is —

a bank that holds a licence under section 7 or 79 of the Banking Act 1970, or a merchant bank approved under section 28 of the Monetary Authority of Singapore Act 1970 on or before 30 June 2021, which is a financial sector incentive company; or

a person who is neither a resident of nor a permanent establishment in Singapore;

arranging interest rate or currency swaps in foreign currencies with —

a bank that holds a licence under section 7 or 79 of the Banking Act 1970, or a merchant bank approved under section 28 of the Monetary Authority of Singapore Act 1970 on or before 30 June 2021, which is a financial sector incentive company;

a person who is neither a resident of nor a permanent establishment in Singapore; or

a branch office outside Singapore of a company resident in Singapore;

managing the funds of the approved office for the purpose of any designated investments, provided that, if the approved office is an associated company not resident in Singapore, unless otherwise allowed by the Minister or approving authority —

not less than 80% of the total number of the issued shares of the approved office are beneficially owned, directly or indirectly, by persons who are neither citizens of Singapore nor resident in Singapore;

the approved office has no permanent establishment in Singapore other than the financial services incentive (headquarter services) company;

the approved office does not carry on business in Singapore;

the approved office does not beneficially own more than 20% of the total number of the issued shares of any company incorporated in Singapore; and

the approved office has less than 20% of the total number of its issued shares beneficially owned, directly or indirectly, by a company which —

has a permanent establishment in Singapore other than the financial sector incentive (headquarter services) company;

carries on business in Singapore; or

beneficially owns more than 20% of the total number of the issued shares of any company incorporated in Singapore.

general management, risk management and administration;

strategic business planning and strategic business development;

operational processing services;

information technology support and technical services;

training and personnel management;

corporate finance advisory services;

economic, financial, investment or market research and analysis;

credit control and administration;

arranging credit facilities for the approved office where the funds for providing the facilities are obtained from —

financial institutions in Singapore; or

the accumulated profits of other approved offices;

providing guarantees, performance bonds, standby letters of credit and services relating to remittances where —

in the case of a guarantee, performance bond or standby letter of credit, the party in whose favour the facility is issued; or

in the case of services relating to remittances, the person to whom the remittances are made,is a financial institution;

arranging interest rate or currency swaps with a financial institution;

managing the funds of the approved office.

at least 25% of the total number of the issued shares of the first-mentioned company are beneficially owned, directly or indirectly, by the financial sector incentive (headquarter services) company; or

at least 25% of the total number of the issued shares of the financial sector incentive (headquarter services) company are beneficially owned, directly or indirectly, by the first-mentioned company.

[Deleted by S 487/2021 wef 01/07/2021](b)on or after 17th February 2006, managing the funds of an approved company for the purpose of any designated investments, or providing investment advisory services to an approved company in respect of any designated investments;

[Deleted by S 487/2021 wef 01/07/2021]

managing the funds of the second-mentioned company for the purpose of any designated investment;

providing investment advisory services to the second-mentioned company in respect of designated investments; or

arranging, on behalf of the second-mentioned company, any loan of designated securities under a securities lending arrangement in writing to a financial sector incentive (standard tier) company or another financial sector incentive (fund management) company,provided that —

the second-mentioned company was incorporated at any time between 18th February 2005 and 17th February 2010 (both dates inclusive);

the date of incorporation of the second-mentioned company is stated in its charter, statute or memorandum and articles or other instrument constituting it or defining its constitution;

at the date of incorporation of the second-mentioned company, the first-mentioned company was already an approved start-up company;

the second-mentioned company has been managed by the first-mentioned company since the date of incorporation of the second-mentioned company; and

the second-mentioned company was not incorporated with the avoidance or reduction of tax chargeable under the Act as its main purpose or one of its main purposes.

managing the funds of the trust fund for the purpose of any designated investment;

providing investment advisory services to the trust fund in respect of designated investments; or

arranging, on behalf of the trust fund, any loan of designated securities under a securities lending arrangement in writing to a financial sector incentive (standard tier) company or another financial sector incentive (fund management) company,provided that —

the trust fund was constituted at any time between 18th February 2005 and 17th February 2010 (both dates inclusive);

the date of constitution of the trust fund is stated in the relevant trust instrument;

at the date of constitution of the trust fund, the company was already an approved start-up company;

the trust fund has been managed by that company since the constitution of that trust fund; and

the trust fund was not constituted with the avoidance or reduction of tax chargeable under the Act as its main purpose or one of its main purposes.

managing the funds of a prescribed person for the purpose of any designated investments, provided the prescribed person has no non-qualifying investor as at the relevant day of the basis period of the prescribed person for the relevant year of assessment;

managing the funds of an approved company for the purpose of any designated investments, provided the approved company has no non-qualifying investor as at the relevant day of the basis period of the approved company for the relevant year of assessment;

subject to regulation 7, managing the funds of a trustee of a prescribed trust fund for the purpose of any designated investments, where the payments for those services are not borne, directly or indirectly, by a person resident in Singapore or by a permanent establishment in Singapore (other than a fund manager of, or a trustee in its capacity as the trustee of the prescribed trust fund);

providing investment advisory services to a prescribed person in respect of any designated investments (including through a fund manager outside Singapore), provided the prescribed person has no non-qualifying investor as at the relevant day of the basis period of the prescribed person for the relevant year of assessment;

providing investment advisory services to an approved company in respect of any designated investments (including through a fund manager outside Singapore), provided the approved company has no non-qualifying investor as at the relevant day of the basis period of the approved company for the relevant year of assessment;

subject to regulation 7, providing investment advisory services to a trustee of a prescribed trust fund in respect of any designated investments, where the payments for those services are not borne, directly or indirectly, by a person resident in Singapore or by a permanent establishment in Singapore (other than a fund manager of, or a trustee in its capacity as the trustee of the prescribed trust fund);

subject to regulation 7, arranging on behalf of a trustee of a prescribed trust fund, any loan of designated securities under a securities lending arrangement in writing to a financial sector incentive (standard tier) company or another financial sector incentive (fund management) company, where the payments for the services are not borne, directly or indirectly, by a person resident in Singapore or by a permanent establishment in Singapore;

subject to regulation 7, providing investment advisory services to a trustee of a prescribed trust fund through a fund manager outside Singapore in respect of designated investments, where the payments for those services are not borne, directly or indirectly, by a person resident in Singapore or by a permanent establishment in Singapore.

managing the funds of an approved person for the purpose of any designated investments; (b)providing investment advisory services to an approved person in respect of any designated investments (including through a fund manager outside Singapore).

managing the funds of the approved master fund or an approved feeder fund of an approved master‑feeder fund structure, for the purpose of any designated investments;

providing investment advisory services to the approved master fund or an approved feeder fund of an approved master‑feeder fund structure in respect of any designated investments (including through a fund manager outside Singapore).

managing the funds of the approved master fund, an approved feeder fund, an approved 1st tier SPV, an approved 2nd tier SPV or an approved eligible SPV of an approved master‑feeder fund‑SPV structure, for the purpose of any designated investments;

providing investment advisory services to the approved master fund, an approved feeder fund, an approved 1st tier SPV, an approved 2nd tier SPV or an approved eligible SPV of an approved master‑feeder fund‑SPV structure in respect of any designated investments (including through a fund manager outside Singapore);

managing the funds of the approved master fund, an approved 1st tier SPV, an approved 2nd tier SPV or an approved eligible SPV of an approved master fund‑SPV structure, for the purpose of any designated investments;

providing investment advisory services to the approved master fund, an approved 1st tier SPV, an approved 2nd tier SPV or an approved eligible SPV of an approved master fund‑SPV structure in respect of any designated investments (including through a fund manager outside Singapore).

managing the funds of the following persons:

a prescribed person;

an approved company;

an approved person;

the approved master fund or an approved feeder fund of an approved master-feeder fund structure;

the approved master fund, an approved feeder fund, an approved 1st tier SPV, an approved 2nd tier SPV or an approved eligible SPV of an approved master-feeder fund-SPV structure;

the approved master fund, an approved 1st tier SPV, an approved 2nd tier SPV or an approved eligible SPV of an approved master fund-SPV structure;

providing investment advisory services (including through another fund manager) to the following persons:

a prescribed person;

an approved company;

an approved person;

the approved master fund or an approved feeder fund of an approved master-feeder fund structure;

the approved master fund, an approved feeder fund, an approved 1st tier SPV, an approved 2nd tier SPV or an approved eligible SPV of an approved master-feeder fund-SPV structure;

the approved master fund, an approved 1st tier SPV, an approved 2nd tier SPV or an approved eligible SPV of an approved master fund-SPV structure.

1st September 2007; or

where an option has been exercised under regulation 8 of the Income Tax (Exemption of Income of Approved Companies Arising from Funds Managed by Fund Manager in Singapore) Regulations 2010 (G.N. No. S 8/2010), the date which the Income Tax (Exemption of Income of Approved Companies from Funds Managed by Fund Manager) Regulations 2007 (G.N. No. S 628/2007) cease to apply.

a company referred to in paragraph (b)(i) of the definition of “foreign investor” in regulation 2 in which any designated person is a shareholder and of which more than 20% of the total number of the issued shares are beneficially owned, directly or indirectly, by persons who are not individuals or companies referred to in paragraph (a) or (b), as the case may be, of that definition and by designated persons;

a trust fund referred to in paragraph (c) of the definition of “foreign investor” in regulation 2 in which any designated person is a beneficiary and of which more than 20% of the value is beneficially held, directly or indirectly, by persons who are not individuals or companies referred to in paragraph (a) or (b), as the case may be, of that definition and by designated persons,the amount of fees and commissions which is chargeable with tax at the concessionary rate of 10% shall be computed in accordance with the following formula:where Ais the number of issued shares of the company referred to in paragraph ( a), the value of issued securities of the company referred to in paragraph (aa) or the value of the trust fund referred to in paragraph (b), as the case may be, which are not beneficially owned or held, directly or indirectly, by persons who are not referred to in paragraphs (a) and (b) of the definition of “foreign investor” in regulation 2 or by designated persons;Bis the total number of issued shares of the company referred to in paragraph (a), the total value of issued securities of the company referred to in paragraph (aa) or the total value of the trust fund referred to in paragraph (b), as the case may be; and”;Cis the amount of fees and commissions derived from the provision of the services referred to in regulation 4(1)(l) or (m) or 6(1)or (2E) to the foreign investor.

a company incorporated before 15th February 2007, in which any designated person is a shareholder and of which more than 20% of the total number of the issued shares are beneficially owned, directly or indirectly, by persons who are citizens of Singapore or resident in Singapore and by designated persons; or

a company incorporated on or after 15th February 2007, in which any designated person is a shareholder and of which more than 20% of the total value of the issued securities are beneficially owned, directly or indirectly, by persons who are citizens of Singapore or resident in Singapore and by designated persons,the amount of fees and commissions which is chargeable with tax at the concessionary rate of 10% shall be computed in accordance with the following formula:where Dis the number of issued shares of the company referred to in sub-paragraph (a) or the value of issued securities of the company referred to in sub-paragraph (b), as the case may be, which are not beneficially owned or held, directly or indirectly, by persons who are citizens of Singapore or resident in Singapore or by designated persons;Eis the total number of issued shares of the company referred to in sub-paragraph (a) or the total value of issued securities of the company referred to in sub-paragraph (b), as the case may be; andFis the amount of fees and commissions derived from the provision of the services referred to in regulation 4(2D) or 6(1)(b) to the approved company.

a company referred to in paragraph (b)(i) of the definition of “foreign investor” in regulation 2(1) where —

a designated person is a shareholder of the company; and (ii)more than 20% of the total number of the issued shares in the company are beneficially owned, directly or indirectly —

by persons who are not individuals or companies referred to in paragraph (a) or (b), as the case may be, of that definition; and

by designated persons;

a company referred to in paragraph (b)(ii) of the definition of “foreign investor” in regulation 2(1) where —

a designated person is a shareholder of the company; and (ii)more than 20% of the total value of the issued securities of the company are beneficially owned, directly or indirectly —

by persons who are not individuals or companies referred to in paragraph (a) or (b), as the case may be, of that definition; and

by designated persons; or

a trust fund referred to in paragraph (c) of the definition of “foreign investor” in regulation 2(1) where —

a designated person is a beneficiary of the fund; and (ii)more than 20% of the value of the fund is beneficially held, directly or indirectly —

by persons who are not individuals or companies referred to in paragraph (a) or (b), as the case may be, of that definition; and

by designated persons,the amount of fees and commissions which is chargeable with tax at the concessionary rate of 12% shall be computed in accordance with the formulawhere Ais the number of issued shares of the company referred to in sub-paragraph (a), the value of issued securities of the company referred to in sub-paragraph (b) or the value of the trust fund referred to in sub-paragraph (c), as the case may be, which are not beneficially owned or held, directly or indirectly, by persons who are not individuals or companies referred to in paragraph (a) or (b), as the case may be, of the definition of “foreign investor” in regulation 2(1) or by designated persons;Bis the total number of issued shares of the company referred to in sub-paragraph (a), the total value of issued securities of the company referred to in sub-paragraph (b) or the total value of the trust fund referred to in sub-paragraph (c), as the case may be; andCis the amount of fees and commissions derived from the provision of the services referred to in sub-paragraph (m), (r) or (y) of Part 1 of the Fourth Schedule or sub‑paragraph (n), (s) or (z) of the Fifth Schedule, as the case may be, to the foreign investor.

any designated person is a beneficiary of that trust fund; and (b)more than 20% of the total value of that trust fund is beneficially held, directly or indirectly —

by persons who are citizens of Singapore or resident in Singapore; and

by designated persons,the amount of fees and commissions which is chargeable with tax at the concessionary rate of 12% shall be computed in accordance with the formulawhere Dis the value of the trust fund which is not beneficially held, directly or indirectly, by persons who are citizens of Singapore or resident in Singapore or by designated persons;Eis the total value of the trust fund; andFis the amount of fees and commissions derived from the provision of the services referred to in sub-paragraph (p), (s), (w) or (z) of Part 1 of the Fourth Schedule or sub‑paragraph (q), (t), (x) or (za) of the Fifth Schedule, as the case may be, to the trustee of the trust fund.

by a financial sector incentive (bond market) company —

during the period between 1 January 2004 and 31 December 2018 (both dates inclusive), from arranging, underwriting or distributing any qualifying debt securities, subject to the conditions specified in the Income Tax (Qualifying Debt Securities) Regulations (Rg 35);

during the period between 16 February 2008 and 31 December 2018 (both dates inclusive), from trading in any qualifying debt securities or qualifying project debt securities;

during the period between 1 January 2004 and 30 June 2021 (both dates inclusive), by a financial sector incentive (credit facilities syndication) company from arranging, underwriting or granting loans under any syndicated offshore facility which is an offshore credit facility or an offshore guarantee facility, if —

the agreement for the facility is made during the period between 1 January 2004 and 30 June 2021 (both dates inclusive); and

the syndication work in respect of the facility is carried out substantially in Singapore;

during the period between 1 January 2004 and 30 June 2021 (both dates inclusive), by a financial sector incentive (credit facilities syndication) company, which is a bank that holds a licence under section 7 or 79 of the Banking Act 1970, or a merchant bank approved under section 28 of the Monetary Authority of Singapore Act 1970 on or before 30 June 2021, from trading in secondary loans under any syndicated offshore facility which is an offshore credit facility or an offshore guarantee facility, if —

the agreement for the facility is made during the period between 1 January 2004 and 30 June 2021 (both dates inclusive); and

the syndication work in respect of the facility is carried out substantially in Singapore;

[Deleted by S 487/2021 wef 01/07/2021](da)during the period between 1 January 2014 and 30 June 2021 (both dates inclusive), by a financial sector incentive (derivatives market) company from the following activities:

trading in financial derivatives; (ii)providing services as an intermediary in connection with transactions relating to financial derivatives;

trading in commodity derivatives or emission derivatives transacted over‑the‑counter with any specified person;

providing services as an intermediary in connection with transactions relating to commodity derivatives or emission derivatives transacted over‑the‑counter between specified persons;

trading in freight derivatives transacted over-the-counter with —

a specified person; or

a shipping enterprise;

providing services as an intermediary in connection with transactions relating to freight derivatives transacted over‑the‑counter between —

specified persons;

shipping enterprises; or

a specified person and a shipping enterprise;

trading with any person in commodity derivatives or freight derivatives transacted over‑the‑counter, where such trade is cleared through the SGX AsiaClear Facility by the Singapore Exchange Derivatives Clearing Limited;

trading in commodity derivatives or emission derivatives transacted on an exchange, where —

the financial sector incentive (derivatives market) company is a member of a qualifying exchange; or

such trade is executed through a specified person who is a member of any exchange, and on behalf of the financial sector incentive (derivatives market) company;

providing services as an intermediary in connection with transactions relating to commodity derivatives or emission derivatives transacted on an exchange between —

specified persons; or