Sources of income
Trading operations carried on partly in Singapore
12.—(1)  Where a non-resident person carries on a trade or business of which only part of the operations is carried on in Singapore, the gains or profits of the trade or business shall be deemed to be derived from Singapore to the extent to which such gains or profits are not directly attributable to that part of the operations carried on outside Singapore.
Non-resident shipping and air transport
(2)  Where a non-resident person carries on —
(a)the business of shipowner or charterer; or
(b)the business of air transport,
and any ship or aircraft owned or chartered by him calls at a port, aerodrome or airport in Singapore, his full profits arising from the carriage of passengers, mails, livestock or goods shipped, or loaded into an aircraft, in Singapore shall be deemed to accrue in Singapore.
(2A)  Subsection (2) shall not apply to passengers, mails, livestock or goods which are brought to Singapore solely for transhipment, or for transfer from one aircraft to another or from an aircraft to a ship or from a ship to an aircraft.
Cable or wireless undertakings
(3)  Where a non-resident person carries on in Singapore the business of transmitting messages by cable or by any form of wireless apparatus, his full profits arising from the transmission in Singapore of any such messages, whether originating in Singapore or elsewhere, to places outside Singapore shall be deemed to accrue in Singapore.
Employment exercised in Singapore
(4)  The gains or profits from any employment exercised in Singapore shall be deemed to be derived from Singapore whether the gains or profits from such employment are received in Singapore or not.
Employment exercised outside Singapore on behalf of Government
(5)  The gains or profits from any employment exercised outside Singapore on behalf of the Government by any individual in the discharge of governmental functions shall be deemed to be derived from Singapore except where such individual is not a citizen or a resident of Singapore.
Interest, etc.
(6)  There shall be deemed to be derived from Singapore —
(a)any interest, commission, fee or any other payment in connection with any loan or indebtedness or with any arrangement, management, guarantee, or service relating to any loan or indebtedness which is —
(i)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 or any immovable property situated outside Singapore; or
(ii)deductible against any income accruing in or derived from Singapore; or
(b)any income derived from loans where the funds provided by such loans are brought into or used in Singapore.
[5/77]
Royalties, etc.
(7)  There shall be deemed to be derived from Singapore —
(a)royalty or other payments in one lump sum or otherwise for the use of or the right to use any movable property;
(b)any payment for the use of or the right to use scientific, technical, industrial or commercial knowledge or information or for the rendering of assistance or service in connection with the application or use of such knowledge or information;
(c)any payment for the management or assistance in the management of any trade, business or profession; or
(d)rent or other payments under any agreement or arrangement for the use of any movable property,
which are 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) or which are deductible against any income accruing in or derived from Singapore.
[5/77]
Commission or other payment of junket promoter
2(8)   Commission or other payment of junket promoterThere shall be deemed to be derived from Singapore any commission or other payment paid to a junket promoter for arranging a junket with a casino operator in Singapore which is —
(a)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; or
(b)deductible against any income accruing in or derived from Singapore.
[10/2006]
[Note: Subsections (8) and (9) shall come into operation on 2nd April 2008 vide S 176/2008.]
2  Subsections (8) and (9), inserted by the Casino Control Act, to come into operation when section 202 of the Casino Control Act is brought into operation.
3(9)   In this section, “casino operator”, “junket” and “junket promoter” have the same meanings as in the Casino Control Act (Cap. 33A)
[10/2006]
3  Subsections (8) and (9), inserted by the Casino Control Act, to come into operation when section 202 of the Casino Control Act is brought into operation.
[Note: Subsections (8) and (9) shall come into operation on 2nd April 2008 vide S 176/2008.]