Exempt income
13.—(1)  There is exempt from tax —
(a)subject to subsection (2) and such conditions as may be prescribed by regulations, the interest derived from —
(i)any qualifying debt securities issued during the period from 28 February 1998 to 31 December 2028 (both dates inclusive) by any person who is not resident in Singapore and who does not have any permanent establishment in Singapore; and
[Act 30 of 2023 wef 30/10/2023]
(ii)any qualifying debt securities issued during the period from 27 February 1999 to 31 December 2028 (both dates inclusive) by any person who is not resident in Singapore and who carries on any operation in Singapore through a permanent establishment in Singapore where the funds used by that person to acquire the qualifying debt securities are not obtained from the operation;
[Act 30 of 2023 wef 30/10/2023]
(aa)subject to subsection (2A) and such conditions as may be prescribed by regulations, the discount from any qualifying debt securities issued during the period from 17 February 2006 to 31 December 2028 (both dates inclusive), by —
(i)any person who is not resident in Singapore and who does not have any permanent establishment in Singapore; or
(ii)any person who is not resident in Singapore and who carries on any operation in Singapore through a permanent establishment in Singapore where the funds used by that person to acquire the qualifying debt securities are not obtained from the operation;
[Act 30 of 2023 wef 30/10/2023]
(ab)subject to subsection (2B) and such conditions as may be prescribed by regulations, any amount payable from any Islamic debt securities which are qualifying debt securities, and issued during the period from 1 January 2005 to 31 December 2028 (both dates inclusive), to any person —
(i)who is not resident in Singapore and who does not have any permanent establishment in Singapore; and
(ii)who is not resident in Singapore and who carries on any operation in Singapore through a permanent establishment in Singapore where the funds used by that person to acquire the qualifying debt securities are not obtained from the operation;
[Act 30 of 2023 wef 30/10/2023]
(b)subject to subsections (2C) and (2D) and such conditions as may be prescribed by regulations —
(i)the interest derived by any person from any qualifying project debt securities issued during the period from 1 November 2006 to 31 December 2025 (both dates inclusive);
[Act 33 of 2022 wef 04/11/2022]
(ii)the discount, early redemption fee and redemption premium derived by any person from any qualifying project debt securities issued during the period from 15 February 2007 to 31 December 2025 (both dates inclusive); and
[Act 33 of 2022 wef 04/11/2022]
[Act 30 of 2023 wef 15/02/2023]
(iii)such other income derived by any person that is directly attributable to qualifying project debt securities issued on or after a prescribed date, as may be prescribed by regulations;
(ba)subject to subsection (2F) and such conditions as may be prescribed by regulations, the early redemption fee and redemption premium from any qualifying debt securities issued during the period from 15 February 2007 to 31 December 2028 (both dates inclusive) that are derived by any person —
(i)who is not resident in Singapore and who does not have any permanent establishment in Singapore; and
(ii)who is not resident in Singapore and who carries on any operation in Singapore through a permanent establishment in Singapore where the funds used by that person to acquire the qualifying debt securities are not obtained from the operation;
[Act 30 of 2023 wef 15/02/2023]
[Act 30 of 2023 wef 30/10/2023]
(bb)subject to subsection (2G) and such conditions as may be prescribed by regulations, such other income directly attributable to qualifying debt securities issued on or after a prescribed date as may be prescribed by regulations, that is derived by any person —
(i)who is not resident in Singapore and who does not have any permanent establishment in Singapore; and
(ii)who is not resident in Singapore and who carries on any operation in Singapore through a permanent establishment in Singapore where the funds used by that person to acquire the qualifying debt securities are not obtained from the operation;
(bc)subject to subsections (2H) and (2HA) and such conditions as may be prescribed by regulations —
(i)the interest, discount, early redemption fee and redemption premium derived by any person from any qualifying debt securities (excluding Singapore Government Securities) which —
(A)are issued during the period from 16 February 2008 to 31 December 2018 (both dates inclusive);
(B)have an original maturity of not less than 10 years;
(C)either —
(CA)if they are issued before 28 June 2013, cannot be redeemed, called, exchanged or converted within 10 years from the date of their issue; or
(CB)if they are issued on or after 28 June 2013, cannot have their tenure shortened to less than 10 years from the date of their issue, except under such circumstances as may be prescribed by regulations; and
(D)cannot be re‑opened with a resulting tenure of less than 10 years to the original maturity date; and
[Act 30 of 2023 wef 15/02/2023]
(ii)such other income, as may be prescribed by regulations, derived by any person that is directly attributable to qualifying debt securities (excluding Singapore Government Securities) which —
(A)are issued on or after such date as may be prescribed by regulations;
(B)have an original maturity of not less than 10 years;
(C)cannot have their tenure shortened to less than 10 years from the date of their issue, except under such circumstances as may be prescribed by regulations; and
(D)cannot be re‑opened with a resulting tenure of less than 10 years to the original maturity date;
(bd)subject to subsection (2I) and such conditions as may be prescribed by regulations, any amount payable to any person from any Islamic debt securities —
(i)which are qualifying debt securities and issued during the period from 16 February 2008 to 31 December 2018 (both dates inclusive); and
(ii)the amount payable from which is not deductible against any income of the issuer of those securities accruing in or derived from Singapore;
(c)the official emoluments payable from Commonwealth funds to members of Commonwealth forces, and to persons in the service of a Commonwealth government, in Singapore, in respect of their offices under such Commonwealth government, if such emoluments are subject to income tax in such Commonwealth country;
(d)any gains or profits arising from sums standing in the SRS account of any SRS member except where section 10G(13) applies;
(e)the income of any institution, authority, person or fund specified in the First Schedule;
(f)the income of —
(i)any bona fide friendly society approved by the Comptroller;
(ii)any co‑operative society registered under the Co‑operative Societies Act 1979;
(g)[Deleted by Act 29 of 2012]
(h)any sum received by way of commutation of pensions granted under any written law relating to pensions in Singapore or, in the case of any other pension scheme, any sum received by way of commutation of pensions by an individual under such a scheme to the extent of such sum as the Comptroller may determine relating to the period of employment of that individual with the employer before 1 January 1993;
(i)sums received by way of death gratuities or as consolidated compensation for death or injuries;
(j)sums standing to the account of an individual in the Central Provident Fund or any approved pension or provident fund designated by the Minister under section 39(8) or withdrawn therefrom;
(ja)sums standing to the account of an individual in an approved pension or provident fund (other than the Central Provident Fund or any approved pension or provident fund designated by the Minister under section 39(8)) to the extent of the sum standing to his or her account as at 31 December 1992 and of such interest on that sum as the Comptroller may determine for the period 1 January 1993 to the date of his or her retirement (both dates inclusive) and which are withdrawn only upon or after his or her retirement in accordance with the rules or constitution of the fund;
(jb)any retiring gratuity received by an individual from an approved pension or provident fund (other than the Central Provident Fund or any approved pension or provident fund designated by the Minister under section 39(8)) to the extent of such amount of the gratuity as the Comptroller may determine relating to the period of employment of that individual with the employer before 1 January 1993;
(jc)[Deleted by Act 32 of 2019]
(jd)any voluntary contribution in cash made in 2013 or any subsequent year by a person of a description prescribed by the Minister, to the medisave account maintained under the Central Provident Fund Act 1953 of a self‑employed individual, up to —
(i)$1,500 per year (for contributions made before 2018); or
(ii)$2,730 per year (for contributions made in 2018 and in each subsequent year),
less any previous contribution that is made to the same medisave account in the same year by the person of the prescribed description in the person’s capacity as an employer (if applicable), and that is not treated as income under section 10B(5A);
(k)sums derived from, or received in, Singapore as pensions, being —
(i)wound or disability pensions granted to members or former members of a Commonwealth force;
(ii)pensions granted to dependent relatives of any such member killed on war service or who died as a result of war service injuries; or
(iii)wound or disability pensions granted to members or former members of civil defence organisations;
(l)pensions granted to any person under the provisions of the Widows’ and Orphans’ Pension Act 1904 or under any approved scheme within the meaning of that Act and pensions paid, by or out of any approved pension or provident fund or society, to or for the benefit of the widow or children of a deceased contributor to such fund or society;
(m)the income of any trade union registered under the Trade Unions Act 1940 insofar as such income is not derived from a trade or business carried on by such trade union;
(ma)the income of any platform work association registered under Part 3 of the Platform Workers Act 2024 which is not derived from a trade or business carried on by the platform work association;
[Act 30 of 2024 wef 01/11/2024]
(n)any income derived in the basis period for any year of assessment before the year of assessment 2018 by any person who is not resident in Singapore from trading in Singapore through consignees in any of the following commodities produced outside Singapore:
(i)rubber;
(ii)copra;
(iii)pepper;
(iv)tin;
(v)tin‑ore;
(vi)gambia;
(vii)sago flour;
(viii)cloves;
(o)[Deleted by Act 32 of 2019]
(oa)payments liable to be made on or after 17 February 2012 to a person not resident in Singapore (excluding any permanent establishment in Singapore) for the charter of any ship (as defined in section 2(1) of the Merchant Shipping Act 1995) under any agreement or arrangement;
(p)[Deleted by Act 34 of 2016]
(q)the investment income of any approved pension or provident fund or society;
(r)the income derived during the period from 3 May 2002 to 31 March 2023 (both dates inclusive) by an individual not resident in Singapore from acting as an arbitrator, and for this purpose, “arbitrator” means an individual appointed for any arbitration which is governed by the Arbitration Act 2001 or the International Arbitration Act 1994 or would have been governed by either of those Acts had the place of arbitration been Singapore;
[Act 33 of 2022 wef 04/11/2022]
(ra)the income derived during the period from 1 April 2015 to 31 March 2023 (both dates inclusive) by a qualifying mediator who is not resident in Singapore, for providing the services of a mediator for a mediation —
(i)that takes place in Singapore; or
(ii)that would have taken place in Singapore but for the settlement of the dispute or withdrawal of the claim in question;
[Act 33 of 2022 wef 04/11/2022]
(rb)the income derived during the period from 1 April 2015 to 31 March 2023 (both dates inclusive) by an individual who is not resident in Singapore, for providing the services of a mediator for a qualifying mediation —
(i)that takes place in Singapore; or
(ii)that would have taken place in Singapore but for the settlement of the dispute or withdrawal of the claim in question;
[Act 33 of 2022 wef 04/11/2022]
(s)[Deleted by Act 39 of 2017]
(t)the income derived on or after 20 August 1968 from interest on moneys held on deposit in an approved bank in Singapore by —
(i)a non‑resident individual; and
(ii)a person, other than an individual, if that person does not, by itself or in association with others, carry on a business in Singapore and does not have a permanent establishment in Singapore;
(ta)the income derived from interest on moneys held on deposit in an approved bank in Singapore by a non‑resident person (not being an individual nor a permanent establishment in Singapore) who carries on any operation in Singapore through a permanent establishment in Singapore if the funds used by that person to make the deposit are not obtained from the operation;
(u)[Deleted by Act 34 of 2016]
(ua)[Deleted by Act 34 of 2016]
(v)the interest received from such Asian Dollar Bonds issued on or before 31 December 2018 as may be approved in writing by the Minister or such person as the Minister may appoint if the interest is received by —
(i)a non‑resident individual; and
(ii)a person, other than an individual, if that person does not, by itself or in association with others, carry on a business in Singapore and does not have a permanent establishment in Singapore;
(w)the income derived from an employment exercised on board a Singapore ship, as defined in the Merchant Shipping Act 1995, if the employment is exercised substantially outside Singapore;
(x)the income derived by a person resident in Singapore from any pension granted under any written law relating to pensions in Singapore, or from any pension paid under such other pensions scheme as may be approved by the Minister by notification in the Gazette to the extent of such amount of the pension as the Comptroller may determine relating to the period of employment of that person with the employer before 1 January 1993;
(y)such income as may be prescribed by regulations under section 43A, 43C, 43D or 43H;
(z)[Deleted by Act 29 of 2012]
(za)any dividends paid on or after 1 January 2008 by any company resident in Singapore;
(zb)any subsidy, allowance or benefit provided by an employer to an employee for the attendance by any child of the employee at an early childhood development centre licensed under the Early Childhood Development Centres Act 2017;
(zc)[Deleted by Act 34 of 2016]
(zd)the interest derived on or after 1 January 2005 by any individual from a deposit of moneys held in Singapore with an approved bank or a finance company licensed under the Finance Companies Act 1967;
(ze)the following income derived from Singapore on or after 1 January 2004 by any individual:
(i)any interest from debt securities;
(ii)any discount from debt securities which mature within one year from the date of issue of those securities;
(iii)any income from an annuity, except income from —
(A)any annuity purchased by the employer of an individual in lieu of any pension or other benefit payable during the individual’s employment or upon the individual’s retirement; and
(B)any annuity purchased under SRS;
(iv)any income from any life insurance policy, except income referred to in section 10(3);
(v)any distribution made by the trustee of any collective investment scheme constituted as a unit trust (excluding any real estate investment trust and approved REIT exchange‑traded fund) authorised under section 286 of the Securities and Futures Act 2001 and the units of which are offered to the public for subscription, that is income or deemed to be income of the individual;
(va)any distribution made by the trustee of a collective investment scheme constituted as a unit trust and authorised under section 286 of the Securities and Futures Act 2001, that is an approved REIT exchange‑traded fund and the units of which are offered to the public for subscription, where the distribution —
(A)is not made out of a distribution that is in turn made out of income of the kinds mentioned in section 43(2A)(a)(i), (ii), (iii), (iv) and (v); and
(B)is income or treated as income of the individual;
(vi)any fee or compensatory payment from securities lending or repurchase arrangements,
except where such income is derived through a partnership in Singapore or is derived from the carrying on of a trade, business or profession;
(zf)any amount payable from Islamic debt securities on or after 1 January 2005 to any individual, except where such amount is derived by the individual through a partnership in Singapore or from the carrying on of a trade, business or profession;
(zg)any distribution made by any trustee‑manager of a registered business trust;
(zh)any distribution made by any trustee of a real estate investment trust of any income of the kinds mentioned in section 43(2A)(a)(i), (ii), (iii), (iv) and (v) to an individual, except where such distribution is derived by the individual through a partnership in Singapore or is derived from the carrying on of a trade, business or profession;
(zi)the following income derived from Singapore on or after 17 February 2006 by any individual:
(i)any discount from debt securities;
(ii)any distribution made by any restricted Singapore scheme out of income derived from Singapore or received in Singapore on or after 17 February 2006, that is income or deemed to be income of the individual,
except where such income is derived through a partnership in Singapore or is derived from the carrying on of a trade, business or profession;
(zj)any income from any structured product offered by a financial institution derived from Singapore —
(i)by an individual, in the basis period relating to the year of assessment 2008 and any subsequent year of assessment, except where such income is derived through a partnership in Singapore or is derived from the carrying on of a trade, business or profession;
(ii)by a non‑resident person (not being an individual) if —
(A)it does not, by itself or in association with others, carry on a business in Singapore, and does not have a permanent establishment in Singapore; and
(B)the contract in respect of the structured product between it and the financial institution takes effect during the period from 1 January 2007 to 31 December 2026 (both dates inclusive) and —
(BA)if such contract is renewed or extended, the period for which the contract is renewed or extended commences before 1 January 2027; or
[Act 33 of 2022 wef 04/11/2022]
(BB)if such contract is varied, the effective date of the variation is before 1 January 2027; or
[Act 33 of 2022 wef 04/11/2022]
(iii)by a non‑resident person (not being an individual) who carries on any operation in Singapore through a permanent establishment in Singapore if —
(A)the funds used by that person to invest in the structured product are not obtained from the operation; and
(B)the contract in respect of the structured product between that person and the financial institution takes effect during the period from 1 January 2007 to 31 December 2026 (both dates inclusive) and —
(BA)if such contract is renewed or extended, the period for which the contract is renewed or extended commences before 1 January 2027; or
[Act 33 of 2022 wef 04/11/2022]
(BB)if such contract is varied, the effective date of the variation is before 1 January 2027;
[Act 33 of 2022 wef 04/11/2022]
(zk)any early redemption fee or redemption premium from debt securities derived from Singapore on or after 15 February 2007 by any individual, except where such income is derived through a partnership in Singapore or is derived from the carrying on of a trade, business or profession;
[Act 30 of 2023 wef 15/02/2023]
(zl)such other income directly attributable to debt securities as may be prescribed by regulations derived from Singapore on or after a prescribed date by any individual, except where such income is derived through a partnership in Singapore or is derived from the carrying on of a trade, business or profession;
(zm)the income of any charity registered or exempt from registration under the Charities Act 1994;
(zn)[Deleted by Act 32 of 2019]
(zo)any sum accrued to a woman on or after 1 January 2011 by way of maintenance in accordance with an order of court or a deed of separation;
(zp)any contribution to the Central Provident Fund in respect of an individual, and any cash payment to an individual, made by the Government under the Workfare Bonus Scheme, the Workfare Special Payment scheme, the Workfare Special Bonus scheme or such other similar scheme involving similar contributions or payments by the Government as the Minister may, by notification in the Gazette, approve;
(zq)any contribution to the Central Provident Fund in respect of an individual, and any cash payment to an individual, made by the Government under the Workfare Income Supplement Scheme established under Part 6A of the Central Provident Fund Act 1953;
(zr)any contribution by the Government to the PSE account, or an account in the Central Provident Fund, of an individual who is or was a national serviceman, as part of the National Service Housing, Medical and Education Awards;
(zs)any distribution made to an individual by a trustee of an approved REIT exchange‑traded fund, out of a distribution from a real estate investment trust that is in turn made out of income of the kinds mentioned in section 43(2A)(a)(i), (ii), (iii), (iv) and (v), but not where the firstmentioned distribution is derived by the individual as a partner in a partnership which is in Singapore or is derived from the carrying on of a trade, business or profession;
[Act 30 of 2023 wef 01/01/2024]
(zt)subject to subsection (2J), income of an entity (called in this section a sovereign risk pooling entity) that is established and operated for the sole object of insuring against risks faced by one or more governments (called in this section the insured governments) that arise directly or indirectly from a disaster (whether natural or man‑made), subject to the following conditions:
(i)the sovereign risk pooling entity is not established or operated for the object of deriving a profit and its income and capital may only be applied towards its sole object;
(ii)its capital is provided only by governments, entities wholly‑owned by governments, and organisations that are not established or operated for the object of deriving a profit;
(iii)a government (not being an insured government) or an entity or organisation mentioned in sub‑paragraph (ii) does not enjoy any risk coverage or receive any benefit in any form (including dividends) from the sovereign risk pooling entity;
(iv)benefits of any insurance provided by the sovereign risk pooling entity, as well as any distribution of the entity’s property if it ceases operation, accrue only to the insured governments; and
[Act 30 of 2023 wef 01/01/2024]
(zu)any gains from the sale or disposal of an asset that are treated as income under section 10L and are assessable as the income of an individual under the provisions of this Act.
[37/2014; 2/2016; 34/2016; 19/2017; 39/2017; 45/2018; 32/2019; 41/2020; 27/2021]
[Act 30 of 2023 wef 01/01/2024]
(1A)  To avoid doubt, the reference to a charter of a ship in subsection (1)(oa) excludes a finance lease of the ship.
[41/2020]
(2)  Subsection (1)(a) does not, unless otherwise approved by the Minister or an authorised body, apply to any interest derived from any qualifying debt securities issued during the period from 10 May 1999 to 31 December 2028 (both dates inclusive) where 50% or more of those securities which are outstanding at any time during the life of the issue are beneficially held or funded, directly or indirectly, by related parties of the issuer of those securities and where such interest is derived by —
(a)any related party of the issuer of those securities; or
(b)any other person where the funds used by such person to acquire those securities are obtained, directly or indirectly, from any related party of the issuer of those securities.
[37/2014; 45/2018]
[Act 41 of 2020 wef 06/12/2022]
[Act 30 of 2023 wef 30/10/2023]
(2A)  Subsection (1)(aa) does not, unless otherwise approved by the Minister or an authorised body, apply to any discount derived from any qualifying debt securities where 50% or more of those securities which are outstanding at any time during the life of the issue are beneficially held or funded, directly or indirectly, by related parties of the issuer of those securities and where such discount is derived by —
(a)any related party of the issuer of those securities; or
(b)any other person where the funds used by such person to acquire those securities are obtained, directly or indirectly, from any related party of the issuer of those securities.
[37/2014]
[Act 41 of 2020 wef 06/12/2022]
(2B)  Subsection (1)(ab) does not, unless otherwise approved by the Minister or an authorised body, apply to any amount payable from any Islamic debt securities which are qualifying debt securities where 50% or more of those securities which are outstanding at any time during the life of the issue are beneficially held or funded, directly or indirectly, by related parties of the issuer of those securities and where the amount is payable to —
(a)any related party of the issuer of those securities; or
(b)any other person where the funds used by such person to acquire those securities are obtained, directly or indirectly, from any related party of the issuer of those securities.
[37/2014]
[Act 41 of 2020 wef 06/12/2022]
(2C)  Subsection (1)(b) does not, unless otherwise approved by the Minister or an authorised body, apply to —
(a)any interest derived from any qualifying project debt securities issued during the period from 1 November 2006 to 31 December 2025 (both dates inclusive);
[Act 33 of 2022 wef 04/11/2022]
(b)any discount, early redemption fee or redemption premium derived from any qualifying project debt securities issued during the period from 15 February 2007 to 31 December 2025 (both dates inclusive); or
[Act 33 of 2022 wef 04/11/2022]
[Act 30 of 2023 wef 15/02/2023]
(c)such other income directly attributable to qualifying project debt securities issued on or after a prescribed date, as may be prescribed by regulations,
if 50% or more of those securities which are outstanding at any time during the life of the issue are beneficially held or funded, directly or indirectly, by related parties of the issuer of those securities.
[37/2014; 39/2017]
[Act 41 of 2020 wef 06/12/2022]
(2D)  Subsection (1)(b) does not apply to —
(a)any interest derived from any qualifying project debt securities issued during the period from 1 November 2006 to 31 December 2025 (both dates inclusive);
[Act 33 of 2022 wef 04/11/2022]
(b)any discount, early redemption fee or redemption premium derived from any qualifying project debt securities issued during the period from 15 February 2007 to 31 December 2025 (both dates inclusive); or
[Act 33 of 2022 wef 04/11/2022]
[Act 30 of 2023 wef 15/02/2023]
(c)such other income directly attributable to qualifying project debt securities issued on or after a prescribed date, as may be prescribed by regulations,
if the securities are held by less than 4 persons at any time during the life of the issue, unless —
(d)approval has been granted by the Minister or an authorised body to such application;
[Act 41 of 2020 wef 06/12/2022]
(e)each person holding the securities is either —
(i)a company resident in Singapore; or
(ii)a trustee of a real estate investment trust (REIT), being a trustee that is resident in Singapore and that holds the securities for the benefit of the unitholders of the REIT;
[Act 33 of 2022 wef 04/11/2022]
(f)the company or REIT is listed on the Singapore Exchange either on the date of issue of the securities or within 6 months from that date; and
[Act 33 of 2022 wef 04/11/2022]
(g)the income from the securities received by the company or trustee is declared to be distributable to the shareholders of the company or unitholders of the REIT (as the case may be) within 6 months from the end of the basis period in which it is received.
[37/2014; 39/2017]
[Act 33 of 2022 wef 04/11/2022]
(2E)  Regulations made under subsection (1)(b), (bc) and (bd) may provide for the determination of the amount of income of the person to be exempted and for the deduction of expenses, allowances and losses of the person otherwise than in accordance with this Act.
(2F)  Subsection (1)(ba) does not, unless otherwise approved by the Minister or an authorised body, apply to any early redemption fee or redemption premium derived from any qualifying debt securities where —
(a)50% or more of those securities which are outstanding at any time during the life of the issue are beneficially held or funded, directly or indirectly, by related parties of the issuer of those securities; and
(b)such fee, premium or cost is derived by —
(i)any related party of the issuer of those securities; or
(ii)any other person where the funds used by such person to acquire those securities are obtained, directly or indirectly, from any related party of the issuer of those securities.
[37/2014]
[Act 41 of 2020 wef 06/12/2022]
[Act 30 of 2023 wef 15/02/2023]
(2G)  Subsection (1)(bb) does not, unless otherwise approved by the Minister or an authorised body, apply to such other income directly attributable to qualifying debt securities as may be prescribed by regulations under that provision where —
(a)50% or more of those securities which are outstanding at any time during the life of the issue are beneficially held or funded, directly or indirectly, by related parties of the issuer of those securities; and
(b)such income is derived by —
(i)any related party of the issuer of those securities; or
(ii)any other person where the funds used by such person to acquire those securities are obtained, directly or indirectly, from any related party of the issuer of those securities.
[37/2014]
[Act 41 of 2020 wef 06/12/2022]
(2H)  Subsection (1)(bc) does not, unless otherwise approved by the Minister or an authorised body, apply to any interest, discount, early redemption fee or redemption premium derived from any qualifying debt securities or such other income directly attributable to qualifying debt securities as may be prescribed by regulations under that provision where —
(a)50% or more of those securities which are outstanding at any time during the life of the issue are beneficially held or funded, directly or indirectly, by related parties of the issuer of those securities; and
(b)such income is derived by —
(i)any related party of the issuer of those securities; or
(ii)any other person where the funds used by such person to acquire those securities are obtained, directly or indirectly, from any related party of the issuer of those securities.
[37/2014]
[Act 41 of 2020 wef 06/12/2022]
[Act 30 of 2023 wef 15/02/2023]
(2HA)  Subsection (1)(bc) does not apply to —
(a)any interest, discount, early redemption fee or redemption premium from qualifying debt securities issued on or after 28 June 2013; or
[Act 30 of 2023 wef 15/02/2023]
(b)such other income, directly attributable to qualifying debt securities as may be prescribed by regulations under that provision,
that is derived on or after the date on which the tenure of any portion of those qualifying debt securities is shortened to less than 10 years from the date of their issue, where the shortening of the tenure occurs under such circumstances as may be prescribed by regulations made under that provision.
(2I)  Subsection (1)(bd) does not, unless otherwise approved by the Minister or an authorised body, apply to any amount payable from any Islamic debt securities which are qualifying debt securities where 50% or more of those securities which are outstanding at any time during the life of the issue are beneficially held or funded, directly or indirectly, by related parties of the issuer of those securities and where the amount is payable to —
(a)any related party of the issuer of those securities; or
(b)any other person where the funds used by such person to acquire those securities are obtained, directly or indirectly, from any related party of the issuer of those securities.
[37/2014]
[Act 41 of 2020 wef 06/12/2022]
(2J)  Despite any other provisions of this Act, in determining for any year of assessment the income of a sovereign risk pooling entity whose income is exempt under subsection (1)(zt) —
(a)any outgoings and expenses incurred by the entity in the production of its income for any year of assessment, and allowable under this Act, may only be deducted against its income for that year of assessment, and any excess of such outgoings and expenses over the income must be disregarded; and
(b)the allowances under sections 19, 19A, 20, 21 and 22 relating to the production of its income for a year of assessment may only be deducted against that income, and any excess of such allowances over the income must be disregarded.
[45/2018]
(3)  Nothing in subsection (1) is to be construed to exempt in the hands of the recipients any dividends, interest, bonuses, salaries or wages paid wholly or in part out of income so exempted.
Income made for purpose which will promote or enhance economic or technological development
(4)  Where the Minister is of the opinion that any payment in the nature of any income referred to in section 12(6) or (7) is made for any purpose which will promote or enhance the economic or technological development of Singapore, the Minister may, by notification in the Gazette, provide that the income is, subject to such conditions as the Minister may impose, exempt from tax wholly or in part and either generally or in respect of certain classes of persons; and such income is as from the date and to the extent specified by the notification exempt from tax.
(5)  [Deleted by Act 49 of 2004]
Income derived by short‑term visiting employees
(6)  There is exempt from tax any income accruing in or derived from Singapore in respect of gains or profits from any employment exercised in Singapore for not more than 60 days in the year preceding any year of assessment by a person who is not resident in Singapore in that year of assessment.
(7)  Subsection (6) does not apply to —
(a)the emoluments received by a director of a company; or
(b)the gains or profits of public entertainers, as defined in section 40A, whose visits are not substantially supported from public funds of the government of another country.
Income received from outside Singapore
(7A)  There is exempt from tax any income arising from sources outside Singapore and received in Singapore —
(a)by any individual who is not resident in Singapore; and
(b)on or after 1 January 2004 by any individual who is resident in Singapore if the Comptroller is satisfied that the tax exemption would be beneficial to the individual, but excludes such income received by the individual through a partnership in Singapore.
(8)  Where the conditions specified in subsection (9) are satisfied, there is exempt from tax —
(a)any dividend derived from any territory outside Singapore;
(b)any profit derived from any trade or business carried on by a branch in any territory outside Singapore of a company resident in Singapore; and
(c)any income derived from any professional, consultancy and other services rendered in any territory outside Singapore only if the Comptroller is satisfied that the income is derived, for the purposes of this Act, from outside Singapore,
and received in Singapore —
(d)on or after 1 June 2003 by any person, not being an individual, resident in Singapore;
(e)during 1 June 2003 to 31 December 2003 (both dates inclusive) by any individual resident in Singapore; and
(f)on or after 1 January 2004 by any individual resident in Singapore through a partnership in Singapore.
[37/2014]
(8A)  [Deleted by Act 39 of 2017]
(8B)  [Deleted by Act 39 of 2017]
(8C)  [Deleted by Act 39 of 2017]
(8D)  [Deleted by Act 39 of 2017]
(9)  The conditions referred to in subsection (8) are —
(a)the income is subject to tax of a similar character to income tax (by whatever name called), or qualified domestic minimum top-up tax (but disregarding any excluded top-up tax), under the law of the territory from which the income is received;
[Act 36 of 2024 wef 01/01/2025]
(b)at the time the income is received in Singapore by the person resident in Singapore, the highest rate of tax of a similar character to income tax (by whatever name called) (but disregarding any excluded top-up tax or qualified domestic minimum top-up tax), levied under the law of the territory from which the income is received on any gains or profits from any trade or business carried on by any company in that territory at that time is not less than 15%; and
[Act 36 of 2024 wef 01/01/2025]
(c)the Comptroller is satisfied that the tax exemption would be beneficial to the person resident in Singapore.
(9A)  To avoid doubt, in subsection (9)(a), income is subject to tax if tax has been paid, or tax (not being deferred tax) is to be paid on that income.
(9B)  The Minister or such person as the Minister may appoint may in any particular case waive the condition referred to in subsection (9)(a), subject to such conditions as the Minister or appointed person may impose.
(10)  Where the income referred to in subsection (8) consists of dividends paid by a company, the tax referred to in subsection (9)(a) is —
(a)where the company is resident in the territory from which the dividends are received, the tax paid in that territory by the company in respect of its income out of which the dividends are paid; and
(b)the tax paid on the dividends in the territory from which the dividends are received.
(11)  The Minister may make regulations generally to give full effect to or for carrying out the purposes of subsection (8).
(12)  The Minister may by order —
(a)exempt from tax wholly or in part; or
(b)provide that tax at such concessionary rate of tax be levied and paid on,
the income received by a person resident in Singapore from such source in any country outside Singapore as may be specified in the order.
(12A)  Every order made under subsection (12) still in force on 1 January 2026, that exempts from tax any of the following, applies on or after that date (and despite anything in the order) only to income described in subsection (12B):
(a)any income received in Singapore by the trustee of a real estate investment trust;
(b)any income received in Singapore by the trustee of a sub‑trust of a real estate investment trust where all rights or interests in the property of the sub-trust are held for the benefit of the beneficiaries of the real estate investment trust;
(c)any income received in Singapore by a company incorporated in Singapore the share capital of which is 100% owned (whether directly or indirectly) by the trustee of a real estate investment trust.
[34/2016; 32/2019]
[Act 33 of 2022 wef 04/11/2022]
(12B)  Subsection (12A) applies to income received in Singapore by the trustee or the company and exempt from tax by the order, that is paid out of income or gains —
(a)relating to any immovable property situated outside Singapore that is acquired (directly or indirectly) by the trustee or the company before 1 January 2026; and
(b)derived, either at a time the trustee or the company owns (directly or indirectly) the property, or from the disposal by the trustee or the company of its interest in that property.
[34/2016; 32/2019]
[Act 33 of 2022 wef 04/11/2022]
(12C)  To avoid doubt, any exemption on or after 1 January 2026 referred to in subsection (12A) is subject to the conditions and restrictions of the exemption as prescribed in the order, insofar as those conditions and restrictions remain applicable.
[37/2014; 2/2016; 32/2019]
(13)  An order made under subsection (12) may —
(a)be either general or specific;
(b)prescribe the conditions subject to which the income will be exempt from tax or be taxed at a concessionary rate of tax;
(c)provide that the Minister may require all or any of the conditions referred to in paragraph (b) to be complied with to the Comptroller’s satisfaction;
(d)prescribe a condition requiring the person to satisfy the Comptroller that all or any of the conditions referred to in paragraph (b) have been complied with before the income is received in Singapore.
(13A)  The conditions referred to in subsection (13) need not be included in the order for the purpose of publication in the Gazette.
(14)  [Deleted by Act 19 of 2013]
(15)  The Minister may, at any time, by rules made under section 7, add to, vary or amend the list of commodities mentioned in subsection (1)(n).
(16)  In this section —
“approved bank” means a bank or merchant bank licensed under the Banking Act 1970;
“approved bond intermediary” means a financial institution approved as such by the Minister or such person as the Minister may appoint;
“approved REIT exchange‑traded fund” has the meaning given by section 43(10);
[Deleted by Act 30 of 2023 wef 15/02/2023]
“child”, in relation to an employee, means any legitimate child, illegitimate child, stepchild, child adopted in accordance with any written law relating to the adoption of children and any child whom the employee is the legal guardian;
“debt securities” has the meaning given by section 43H;
“deposit”, in relation to any deposit of moneys referred to in subsection (1)(t), (ta) or (zd) which is made on or after 7 October 2004 and which matures on or after 2 June 2005, means a deposit which falls within the meaning of deposit in section 4B of the Banking Act 1970 and is treated as such by the Monetary Authority of Singapore for the purposes of that section;
“early redemption fee”, in relation to debt securities, qualifying debt securities or qualifying project debt securities, means any fee payable by the issuer of the securities on the early redemption of the securities;
[Act 30 of 2023 wef 15/02/2023]
“finance lease”, in relation to a ship, means a lease of the ship (including any arrangement or agreement made in connection with the lease) that has the effect of transferring substantially the obsolescence, risks or rewards incidental to ownership of the ship to the lessee;
“financial derivative” means a derivative the payoffs of which are linked, whether in whole or in part, to the payoffs or performance of any financial assets, securities, financial instruments or indices, but does not include a derivative the payoffs of which are wholly linked to the payoffs or performance of commodities;
“financial institution” means an institution licensed or approved by the Monetary Authority of Singapore, and includes an institution approved as a Finance and Treasury Centre under section 43E;
“financial sector incentive (bond market) company” means a company approved as such by the Minister or such person as he may appoint;
“financial sector incentive (capital market) company” means a company approved as such by the Minister or an authorised body;
[S 759/2022]
[Act 41 of 2020 wef 06/12/2022]
“financial sector incentive (project finance) company” means a company approved as such by the Minister or such person as the Minister may appoint;
“financial sector incentive (standard tier) company” has the meaning given by section 43H(4);
“Islamic debt securities” has the meaning given by section 43H(4);
“medisave contribution ceiling” has the meaning given by section 39(13);
“national serviceman” has the meaning given by the Enlistment Act 1970;
[Deleted by Act 30 of 2023 wef 15/02/2023]
“PSE account” has the meaning given by the Education Endowment and Savings Schemes Act 1992;
“qualifying debt securities” means —
(a)Singapore Government securities issued during the period from 28 February 1998 to 31 December 2028 (both dates inclusive);
[Act 30 of 2023 wef 30/10/2023]
(b)bonds, notes, commercial papers, certificates of deposits and AT1 instruments within the meaning of section 10I(2), which are arranged in accordance with regulations made for this purpose —
(i)by any financial institution in Singapore and issued during the period from 28 February 1998 to 31 December 2013 (both dates inclusive);
(ii)by any approved bond intermediary and issued —
(A)during the period from 27 February 1999 to 31 December 2028 (both dates inclusive) under any prescribed programme the arrangement of which is completed on or before 31 December 2003; or
[Act 30 of 2023 wef 30/10/2023]
(B)during the period from 27 February 1999 to 31 December 2003 (both dates inclusive) in any other case;
(iii)by any financial sector incentive (bond market) company and issued during the period from 1 January 2004 to 31 December 2018 (both dates inclusive);
[Act 30 of 2023 wef 15/02/2023]
(iv)by any financial sector incentive (standard tier) company or financial sector incentive (capital market) company and issued during the period from 1 January 2014 to 31 December 2023 (both dates inclusive); or
[Act 30 of 2023 wef 15/02/2023]
(v)by any of the following persons and issued during the period from 15 February 2023 to 31 December 2028 (both dates inclusive):
(A)a bank or merchant bank licensed under the Banking Act 1970;
(B)a finance company licensed under the Finance Companies Act 1967;
(C)a person who holds a capital markets services licence under the Securities and Futures Act 2001 to carry on a business in any of the following regulated activities:
(CA)advising on corporate finance;
(CB)dealing in capital markets products;
(D)such other person as may be prescribed by rules made under section 7;
[Act 30 of 2023 wef 15/02/2023]
(c)Islamic debt securities which are arranged in accordance with regulations made for this purpose —
(i)by any financial institution in Singapore and issued during the period from 1 January 2005 to 31 December 2013 (both dates inclusive);
(ii)by any financial sector incentive (bond market) company and issued during the period from 1 January 2005 to 31 December 2018 (both dates inclusive);
[Act 30 of 2023 wef 15/02/2023]
(iii)by any financial sector incentive (standard tier) company or financial sector incentive (capital market) company and issued during the period from 1 January 2014 to 31 December 2023 (both dates inclusive); or
(iv)by any of the following persons and issued during the period from 15 February 2023 to 31 December 2028 (both dates inclusive):
(A)a bank or merchant bank licensed under the Banking Act 1970;
(B)a finance company licensed under the Finance Companies Act 1967;
(C)a person who holds a capital markets services licence under the Securities and Futures Act 2001 to carry on a business in any of the following regulated activities:
(CA)advising on corporate finance;
(CB)dealing in capital markets products;
(D)such other person as may be prescribed by rules made under section 7; or
[Act 30 of 2023 wef 15/02/2023]
(d)debt securities whose values are derived from insured loss events underlying them, that are issued by a Special Purpose Reinsurance Vehicle during the period between 20 December 2018 and 31 December 2028 (both dates inclusive), where —
(i)if the date of issue is between 20 December 2018 and 31 December 2023 (both dates inclusive) — at least 20% of the issue costs for the issue are required to be paid to persons or partnerships carrying on any trade, business or profession in Singapore; or
(ii)if the date of issue is between 1 January 2024 and 31 December 2028 (both dates inclusive) — at least 30% of the issue costs for the issue are required to be paid to persons or partnerships carrying on any trade, business or profession in Singapore,
[Act 30 of 2023 wef 30/10/2023]
but, unless otherwise approved by the Minister or an authorised body, excludes any debt securities issued on or after 10 May 1999 and any Islamic debt securities issued on or after 1 January 2005 which, during its primary launch —
(e)are issued to less than 4 persons; and
(f)50% or more of the issue of debt securities or Islamic debt securities is beneficially held or funded, directly or indirectly, by related parties of the issuer of those debt securities or Islamic debt securities;
[S 759/2022]
[Act 41 of 2020 wef 06/12/2022]
“qualifying mediation” means a mediation that is administered by a body or an organisation that provides services for the conduct of mediation (called in this section a mediation service provider), and that is prescribed under section 7;
“qualifying mediator” means an individual who is certified or accredited under a mediator certification or accreditation scheme prescribed under section 7;
“qualifying project debt securities” means debt securities —
(a)which are arranged in accordance with regulations made for this purpose —
(i)by any financial institution in Singapore and issued during the period from 1 November 2006 to 31 December 2013 (both dates inclusive);
(ii)by any financial sector incentive (bond market) company or financial sector incentive (project finance) company and issued during the period from 1 November 2006 to 31 December 2023 (both dates inclusive);
[Act 33 of 2022 wef 04/11/2022]
[Act 30 of 2023 wef 15/02/2023]
(iii)by any financial sector incentive (standard tier) company or financial sector incentive (capital market) company and issued during the period from 1 January 2014 to 31 December 2023 (both dates inclusive); or
[Act 33 of 2022 wef 04/11/2022]
[Act 30 of 2023 wef 15/02/2023]
(iv)by any of the following persons and issued during the period from 15 February 2023 to 31 December 2025 (both dates inclusive):
(A)a bank or merchant bank licensed under the Banking Act 1970;
(B)a finance company licensed under the Finance Companies Act 1967;
(C)a person who holds a capital markets services licence under the Securities and Futures Act 2001 to carry on a business in any of the following regulated activities:
(CA)advising on corporate finance;
(CB)dealing in capital markets products;
(D)such other person as may be prescribed by rules made under section 7;
[Act 30 of 2023 wef 15/02/2023]
(b)the interest and other income directly attributable to which are funded primarily by cash flows from an infrastructure asset or project prescribed by regulations (called in this definition a prescribed asset or project); and
(c)the proceeds from the issue of which are only used to acquire, develop or invest in a prescribed asset or project, or to refinance a previous borrowing which was only used for that purpose; where the gearing ratio of such prescribed asset or project is approved by the Minister or an authorised body in a case where the debt securities are issued by a person in Singapore or the prescribed asset or project is in Singapore,
[S 759/2022]
[Act 41 of 2020 wef 06/12/2022]
but does not include, except with the approval of the Minister or an authorised body (which approval may be subject to such conditions as the Minister may impose), any debt securities —
(d)which are issued to less than 4 persons; or
(e)50% or more of the issue of which is beneficially held or funded, directly or indirectly, by related parties of the issuer of those debt securities;
[Act 41 of 2020 wef 06/12/2022]
“real estate investment trust” has the meaning given by section 43(10);
“redemption premium”, in relation to debt securities, qualifying debt securities or qualifying project debt securities, means any premium payable by the issuer of the securities on the redemption of the securities upon their maturity or on the early redemption of the securities;
[Act 30 of 2023 wef 15/02/2023]
“registered business trust” and “trustee‑manager” have the meanings given by the Business Trusts Act 2004;
[Deleted by Act 33 of 2022 wef 04/11/2022]
“restricted Singapore scheme” means a collective investment scheme constituted as a unit trust that is a restricted Singapore scheme within the meaning of the regulations made under the Securities and Futures Act 2001 for the purpose of section 305 of that Act;
“securities lending or repurchase arrangement” has the meaning given by section 10H(12);
“Singapore Government securities” has the meaning given by section 43H;
“structured product” means a sum of money paid on terms under which —
(a)it may not be repaid in full and the return from which is, partly or wholly, determined by the performance of any embedded derivative instrument; and
(b)its repayment may be in money or money’s worth,
but does not include any sum paid in respect of any debt securities, units of a real estate investment trust, units of a unit trust, loan, stand‑alone financial derivative or such other financial product as the Minister may by regulations prescribe;
“unit trust” has the meaning given by section 10A.
[37/2014; 2/2016; 39/2017; 45/2018; 32/2019; 1/2020; 41/2020; 27/2021]
(16A)  In paragraph (d) of the definition of “qualifying debt securities” in subsection (16) —
“issue costs”, in relation to an issue of debt securities, means legal fees, modelling fees, arranger or underwriting fees, rating agency fees, audit fees, claim review fees, indenture trustee fees, listing or trustee fees, loss reserve specialist and administrator fees, and other fees that are connected with or incidental to the issue;
“Special Purpose Reinsurance Vehicle” has the meaning given by regulation 2 of the Insurance (General Provisions and Exemptions for Special Purpose Reinsurance Vehicles) Regulations 2018.
[32/2019]
(16B)  In paragraphs (b)(v) and (c)(iv) of the definition of “qualifying debt securities” and paragraph (a)(iv) of the definition of “qualifying project debt securities” in subsection (16), “advising on corporate finance” and “dealing in capital markets products” have the meanings given by the Second Schedule to the Securities and Futures Act 2001.
[Act 30 of 2023 wef 15/02/2023]
(17)  For the purposes of the definitions of “qualifying mediation” and “qualifying mediator” in subsection (16), the Minister may prescribe a description of mediation service providers and a description of mediator certification or accreditation schemes that are set out on a specified website of the Ministry of Law, as amended from time to time.
[2/2016]
(18)  In subsection (2D) —
(a)an umbrella VCC that holds securities for one sub‑fund is treated as a different person from the same umbrella VCC that holds securities for another sub‑fund;
(b)an umbrella VCC that holds securities for one sub‑fund is considered a company that satisfies subsection (2D)(e) and (f) if —
(i)the umbrella VCC is resident in Singapore; and
(ii)the sub‑fund is listed on the Singapore Exchange on the date of issue of the securities or within 6 months from that date;
(c)income that is received by an umbrella VCC from securities held by it for one sub‑fund satisfies subsection (2D)(g) if the income is declared to be distributable to holders of its shares in respect of that sub‑fund within 6 months from the end of the basis period in which the income is received.
[28/2019]
(19)  In paragraph (e) of the definition of “qualifying debt securities” and paragraph (d) of the definition of “qualifying project debt securities” in subsection (16), an umbrella VCC to which securities are issued during their primary launch for the purpose of one sub‑fund, is treated as a different person from the same umbrella VCC to which securities are issued during their primary launch for the purpose of another sub‑fund.
[28/2019]
(20)  A reference in this section to a related party of the issuer of qualifying debt securities or qualifying project debt securities is, if the securities are issued by or to an umbrella VCC in relation to any of its sub‑funds, a reference to a person that is related to the sub‑fund in such manner as may be prescribed by rules made under section 7, and rules made for this purpose may make different provisions for different circumstances.
[28/2019]