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10% tax payable on qualifying income of financial sector incentive (fund management) company

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

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—(1) Subject to regulation 7, tax shall be payable at the rate of 10% on the income of a financial sector incentive (fund management) company derived from the following activities:(a)[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;(c)[Deleted by S 487/2021 wef 01/07/2021](2) Tax shall be payable at the rate of 10% on the income of a financial sector incentive (fund management) company which is an approved start-up fund manager, derived during a period of 12 months from the date of the incorporation, by that company, of a fund in the form of a company not resident in Singapore, from —(a)managing the funds of the second-mentioned company for the purpose of any designated investment;(b)providing investment advisory services to the second-mentioned company in respect of designated investments; or(c)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 —(i)the second-mentioned company was incorporated at any time between 18th February 2005 and 17th February 2010 (both dates inclusive);(ii)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;(iii)at the date of incorporation of the second-mentioned company, the first-mentioned company was already an approved start-up company;(iv)the second-mentioned company has been managed by the first-mentioned company since the date of incorporation of the second-mentioned company; and(v)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.(3) Tax shall be payable at the rate of 10% on the income of a financial sector incentive (fund management) company which is an approved start-up fund manager, derived during a period of 12 months from the date of the constitution, by that company, of a trust fund, from —(a)managing the funds of the trust fund for the purpose of any designated investment;(b)providing investment advisory services to the trust fund in respect of designated investments; or(c)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 —(i)the trust fund was constituted at any time between 18th February 2005 and 17th February 2010 (both dates inclusive);(ii)the date of constitution of the trust fund is stated in the relevant trust instrument;(iii)at the date of constitution of the trust fund, the company was already an approved start-up company;(iv)the trust fund has been managed by that company since the constitution of that trust fund; and(v)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.(4) Tax shall be payable at the rate of 10% on the income of a financial sector incentive (fund management) company derived during the period between 1 September 2007 and 30 June 2021 (both dates inclusive) from any of the following activities:(a)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;(b)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;(c)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);(d)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;(e)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;(f)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);(g)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;(h)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.(4A) Subject to this regulation, tax shall be payable at the rate of 10% on the income of a financial sector incentive (fund management) company derived during the period between 1 April 2009 and 30 June 2021 (both dates inclusive) from any of the following activities:(a)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).(4B) Subject to this regulation, tax is payable at the rate of 10% on the income of a financial sector incentive (fund management) company derived during the period between 7 July 2010 and 30 June 2021 (both dates inclusive) from any of the following activities:(a)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;(b)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).(4C) Subject to this regulation, tax is payable at the rate of 10% on the income of a financial sector incentive (fund management) company derived during the period between 1 April 2015 and 30 June 2021 (both dates inclusive) from any of the following activities:(a)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;(b)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);(c)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;(d)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).(4D) Tax is payable at the rate of 10% on the income of a financial sector incentive (fund management) company derived on or after 1 July 2021 from the following activities:(a)managing the funds of the following persons:(i)a prescribed person;(ii)an approved company;(iii)an approved person;(iv)the approved master fund or an approved feeder fund of an approved master-feeder fund structure;(v)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;(vi)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;(b)providing investment advisory services (including through another fund manager) to the following persons:(i)a prescribed person;(ii)an approved company;(iii)an approved person;(iv)the approved master fund or an approved feeder fund of an approved master-feeder fund structure;(v)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;(vi)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.(5) The rate of tax of 10% referred to in paragraph (1) shall not apply to any income from activities referred to in sub-paragraph (b) of that paragraph if derived on or after —(a)1st September 2007; or(b)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.

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