Income Tax (Amendment) Act 2019 - Singapore Statutes Online

REPUBLIC OF SINGAPORE

GOVERNMENT GAZETTE

ACTS SUPPLEMENT

Published by Authority

NO. 39]

Friday, December 6

[2019

The following Act was passed by Parliament on 7 October 2019 and assented to by the President on 29 October 2019:—

Income Tax (Amendment) Act 2019

(No. 32 of 2019)

I assent.

HALIMAH YACOB,

President.

29 October 2019.

Date of Commencement: 2 December 2019 Sections 2, 5, 6(a), (b), (c) and (d), 7, 11, 12, 13(a) and (b), 21(a) to (k), 22, 23, 25, 28(c), 29, 30(a), 32, 33, 35, 36(b), 37, 39 to 44, 46 and 47

An Act to amend the Income Tax Act (Chapter 134 of the 2014 Revised Edition) and to make related amendments to the Stamp Duties Act (Chapter 312 of the 2006 Revised Edition).

Be it enacted by the President with the advice and consent of the Parliament of Singapore, as follows:

Short title and commencement

1.—(1) This Act is the Income Tax (Amendment) Act 2019.

(2) Sections 28(a) and (b) and 45 are deemed to have come into operation on 1 January 2018.

(3) Sections 4, 19, 20, 26 and 31 are deemed to have come into operation on 12 November 2018.

(4) Sections 9, 16, 27 and 34 are deemed to have come into operation on 12 December 2018.

(5) Section 6(e) and (f) is deemed to have come into operation on 20 December 2018.

(6) Section 21(l) is deemed to have come into operation on 31 December 2018.

(7) Section 24 is deemed to have come into operation on 1 January 2019.

(8) Sections 3 and 17 are deemed to have come into operation on 19 February 2019.

(9) Sections 8, 10, 13(c) and (d), 14, 15 and 18 are deemed to have come into operation on 1 April 2019.

(10) Sections 30(b) and 36(a) are deemed to have come into operation on 1 July 2019.

(11) Section 38 comes into operation on 1 January 2020.

Amendment of section 2

2. Section 2(1) of the Income Tax Act (called in this Act the principal Act) is amended by inserting, immediately after the word “sections” in the definition of “Comptroller”, “34F(9),”.

Amendment of section 10B

3. Section 10B of the principal Act is amended by inserting, immediately after subsection (1), the following subsection:

“(1A) No unit trust may be approved as an approved unit trust under this section after 18 February 2019.”.

Amendment of section 10F

4. Section 10F of the principal Act is amended —

(a)

by deleting the words “or FRS 115 construction or upgrade services” in subsections (1B), (1C)(a) and (1D)(a) and substituting in each case the words “FRS 115 construction or upgrade services, or SFRS(I) 15 construction or upgrade services”; and

(b)

by deleting the definitions of “FRS 11”, “FRS 17”, “FRS 115”, “FRS 116”, “INT FRS 104”, “INT FRS 112”, “SFRS(I) 1‑17”, “SFRS(I) 16”, “SFRS(I) INT 4” and “SFRS(I) INT 12” in subsection (2) and substituting the following definitions:

“ “FRS 11”, “FRS 17”, “FRS 115”, “FRS 116”, “INT FRS 104”, “INT FRS 112”, “SFRS(I) 1‑17”, “SFRS(I) 15”, “SFRS(I) 16”, “SFRS(I) INT 4” and “SFRS(I) INT 12” mean the financial reporting standards known respectively as —

(a)	Financial Reporting Standard 11 (Construction Contracts);
(b)	Financial Reporting Standard 17 (Leases);
(c)	Financial Reporting Standard 115 (Revenue from Contracts with Customers);
(d)	Financial Reporting Standard 116 (Leases);
(e)	Interpretation of Financial Reporting Standard 104 (Determining whether an Arrangement contains a Lease);
(f)	Interpretation of Financial Reporting Standard 112 (Service Concession Arrangements);
(g)	Singapore Financial Reporting Standard (International) 1‑17 (Leases);
(h)	Singapore Financial Reporting Standard (International) 15 (Revenue from Contracts with Customers);
(i)	Singapore Financial Reporting Standard (International) 16 (Leases);
(j)	Singapore Financial Reporting Standard (International) Interpretation 4 (Determining whether an Arrangement contains a Lease); and
(k)	Singapore Financial Reporting Standard (International) Interpretation 12 (Service Concession Arrangements),

that are made by the Accounting Standards Council under Part III of the Accounting Standards Act (Cap. 2B), as amended from time to time;

“SFRS(I) 15 construction or upgrade services” means any construction or upgrade services (as the case may be) to which SFRS(I) 15 applies.”.

Amendment of section 12

5. Section 12 of the principal Act is amended by inserting, immediately after subsection (7AA), the following subsection:

“(7AB) Subsection (7)(d) excludes any rent or other payments under any agreement or arrangement for the use outside Singapore of any tangible movable property, where —

(a)

such use is for or incidental to the purpose of a trip to a country outside Singapore that is made for the purpose of a trade, business, profession or vocation carried on —

(i)	in Singapore by a person resident in Singapore; or
(ii)	through a permanent establishment in Singapore; or

(b)

such use is for or incidental to the purpose of maintaining a representative office outside Singapore that is maintained for the purpose of a trade, business, profession or vocation carried on in Singapore.”.

Amendment of section 13

6. Section 13 of the principal Act is amended —

(a)

by deleting the words “on or before 31 March 2020” in subsection (1)(zh);

(b)

by deleting the words “during the period from 1 July 2018 to 31 March 2020 (both dates inclusive)” in subsection (1)(zs);

(c)

by deleting the words “1 April 2020” in subsections (12A) and (12B)(a) and substituting in each case the words “1 January 2026”;

(d)

by deleting the words “1st April 2020” in subsection (12C) and substituting the words “1 January 2026”;

(e)

by deleting the comma at the end of paragraph (c) of the definition of “qualifying debt securities” in subsection (16) and substituting the word “; or”, and by inserting immediately thereafter the following paragraph:

“(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 from 20 December 2018 to 31 December 2023 (both dates inclusive), where 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,”; and

(f)

by inserting, immediately after subsection (16), the following subsection:

“(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 (G.N. No. S 837/2018).”.

Amendment of section 13A

7. Section 13A of the principal Act is amended —

(a)

by inserting, immediately after subsection (1CK), the following subsection:

“(1CL) The income of a shipping enterprise mentioned in this section includes income derived on or after 12 December 2018 by the shipping enterprise from foreign exchange and risk management activities that are carried out in connection with or incidental to the finance leasing of a Singapore ship for use outside the limits of the port of Singapore.”;

(b)

by deleting the definition of “finance leasing” in subsection (16) and substituting the following definition:

“ “finance leasing” means —

(a)	in relation to a container, a lease of the container (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 container to the lessee; and
(b)	in relation to a ship, 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;”;

(c)

by deleting the word “or” at the end of paragraph (a)(iv) of the definition of “operation” in subsection (16); and

(d)

by deleting the word “and” at the end of sub‑paragraph (v) of paragraph (a) of the definition of “operation” in subsection (16) and substituting the word “or”, and by inserting immediately thereafter the following sub‑paragraph:

“(vi)

the finance leasing of the ship for use outside the limits of the port of Singapore, but only where the income in question is derived from the finance leasing on or after 12 December 2018; and”.

Amendment of section 13CA

8. Section 13CA(10) of the principal Act is amended by deleting the words “1st April 2019” in paragraphs (a) and (b)(i) and substituting in each case the words “1 January 2025”.

Amendment of section 13F

9. Section 13F of the principal Act is amended —

(a)

by deleting the word “and” at the end of subsection (1)(p);

(b)

by deleting the full‑stop at the end of paragraph (q) of subsection (1) and substituting a semi‑colon, and by inserting immediately thereafter the following paragraphs:

“(r)

on or after 12 December 2018 from —

(i)	the finance leasing of any foreign ship to any person where the ship is used by the person for the carriage of passengers, mail, livestock or goods outside the limits of the port of Singapore;
(ii)	the finance leasing of any foreign dredger, foreign seismic ship, or any foreign ship used for offshore oil or gas activity to any person where the dredger, seismic ship or ship is used by the person for the person’s operation outside the limits of the port of Singapore;
(iii)	the finance leasing of any foreign ship to any person where the ship is used by the person for towage and salvage operations carried out outside the limits of the port of Singapore; and
(iv)	the finance leasing of any foreign ship for offshore renewable energy activity or offshore mineral activity to any person, where the ship is used by the person for the person’s operation outside the limits of the port of Singapore; and

(s)

on or after 12 December 2018 from foreign exchange and risk management activities which are carried out in connection with and incidental to an activity mentioned in paragraph (r).”; and

(c)

by deleting the words “(n) to (q)” in subsection (4) and substituting the words “(n) to (s)”.

Amendment of section 13G

10. Section 13G of the principal Act is amended —

(a)	by deleting the words “1st April 2019” in subsections (6)(a), (b), (c)(i) and (d)(i) and (7) and substituting in each case the words “1 January 2025”; and
(b)	by deleting the words “31st March 2019” in subsection (6)(c)(ii) and (d)(ii) and substituting in each case the words “31 December 2024”.

Amendment of section 13H

11. Section 13H of the principal Act is amended —

(a)

by deleting subsection (2C) and substituting the following subsections:

“(2C) The Minister or such person as the Minister may appoint may, subject to such conditions as the Minister or person may impose, approve a venture company as an approved venture company for the purposes of this section.

(2D) No approval may be granted to a venture company on or after 1 April 2020.”; and

(b)

by deleting the definition of “approved” in subsection (18).

Amendment of section 13N

12. Section 13N of the principal Act is amended —

(a)

by deleting paragraph (d) of subsection (3) and substituting the following paragraph:

“(d)

if he is resident in Singapore in any year of assessment between the years of assessment 2006 and 2020 (both years inclusive), but is not resident in Singapore for all the 3 years of assessment immediately preceding that year of assessment, for a period of 5 consecutive years commencing from that year of assessment in which he is resident in Singapore.”;

(b)

by inserting, immediately after the words “subject to” in subsection (4), the words “subsection (4A) and”; and

(c)

by inserting, immediately after subsection (4), the following subsection:

“(4A) No approval under subsection (4) may be granted for any application made on or after 1 January 2025.”.

Amendment of section 13O

13. Section 13O of the principal Act is amended —

(a)

by deleting sub-paragraph (iii) of paragraph (b) of the definition of “foreign account” in subsection (3) and substituting the following sub‑paragraph:

“(iii)

does not in the basis period —

(A)	in the case of any year of assessment before 2021, carry on a business in Singapore; or
(B)	in the case of the year of assessment 2021 or a subsequent year of assessment, carry on a business in Singapore or outside Singapore;”;

(b)

by deleting sub-paragraph (B) of paragraph (b)(v) of the definition of “foreign account” in subsection (3) and substituting the following sub‑paragraph:

“(B)

carries on in the basis period —

(BA)	in the case of any year of assessment before 2021, a business in Singapore; or
(BB)	in the case of the year of assessment 2021 or a subsequent year of assessment, a business in Singapore or outside Singapore; or”;

(c)

by deleting the words “1st April 2019” in subsections (5)(a), (b), (c)(i) and (d)(i), (6) and (8) and substituting in each case the words “1 January 2025”; and

(d)

by deleting the words “31st March 2019” in subsection (5)(c)(ii) and (d)(ii) and substituting in each case the words “31 December 2024”.

Amendment of section 13Q

14. Section 13Q of the principal Act is amended —

(a)	by deleting the words “1st April 2019” in subsections (4)(a), (b), (c)(i) and (d)(i), (5) and (7) and substituting in each case the words “1 January 2025”; and
(b)	by deleting the words “31st March 2019” in subsection (4)(c)(ii) and (d)(ii) and substituting in each case the words “31 December 2024”.

Amendment of section 13R

15. Section 13R(2) of the principal Act is amended by deleting the words “31st March 2019” and substituting the words “31 December 2024”.

Amendment of section 13S

16. Section 13S of the principal Act is amended —

(a)

by deleting the words “(1B) and” in subsection (1) and substituting the words “(1G) and”;

(b)

by deleting the word “and” at the end of paragraph (cb) of subsection (1), and by inserting immediately thereafter the following paragraphs:

“(cc)

on or after 12 December 2018 from the chartering or finance leasing by the approved shipping investment enterprise of any sea‑going ship, for use by the lessee outside the limits of the port of Singapore, if the ship was —

(i)	acquired by an approved related party before or during the period of its approval under subsection (3); and
(ii)	chartered, or leased under a finance lease, by the approved related party to the approved shipping investment enterprise;

(cd)

on or after 12 December 2018 from foreign exchange and risk management activities that are carried out in connection with and incidental to an activity mentioned in paragraph (cc); and”;

(c)

by renumbering subsections (1AA) and (1B) as subsections (1F) and (1G), respectively;

(d)

by inserting, immediately after subsection (1A), the following subsections:

“(1B) In relation to income mentioned in subsection (1)(cc) or (cd), subsection (1) continues to apply to a shipping investment enterprise the approval of which has expired or been withdrawn, but that continues to derive such income, if both the shipping investment enterprise and the related party mentioned in subsection (1)(cc) have, by the date of the expiry or before the withdrawal, fulfilled all the conditions of their respective approvals under subsection (3).

(1C) For the purpose of subsection (1B), the shipping investment enterprise is treated under this section as an approved shipping investment enterprise.

(1D) Subsection (1)(ca) and (cc) does not apply to income derived on or after 12 December 2018 from the chartering or finance leasing of a sea‑going ship that is acquired by the approved shipping investment enterprise or the approved related party by way of a finance lease entered into with an entity that was not an approved related party.

(1E) Subsections (1)(cc) and (cd) and (1B) apply to income derived by an approved shipping investment enterprise in relation to a ship acquired by the related party before the period of the approval of the related party, if and only if the approved shipping investment enterprise is approved on or after 1 April 2008.”;

(e)

by inserting, immediately after the words “shipping investment enterprise” in subsection (2), the words “or a related party of an approved shipping investment enterprise”;

(f)

by deleting the words “and (cb)” in subsection (6) and substituting the words “, (cb), (cc) and (cd)”;

(g)

by inserting, immediately after the words “any sea‑going ship” in the definition of “finance leasing” in subsection (20), the words “(including any arrangement or agreement in connection with such leasing)”;

(h)

by inserting, immediately after the definition of “registered business trust” in subsection (20), the following definition:

“ “related party”, in relation to an approved shipping investment enterprise, means any entity that is related to the approved shipping investment enterprise in such manner as may be prescribed by rules made under section 7;”;

(i)

by deleting the definition of “tax exempt period” in subsection (20) and substituting the following definition:

“ “tax exempt period”, in relation to an approved shipping investment enterprise, means —

(a)

in a case where the enterprise is approved on or after 1 April 2008 and —

(i)	acquired; or
(ii)	chartered, or leased under a finance lease, from a related party,

a sea-going ship for use outside the limits of the port of Singapore before the date of approval of the enterprise — the period from the date of that approval to the date where no income of any sea‑going ship of that enterprise is eligible for exemption from tax under subsection (1) (both dates inclusive); or

(b)

in any other case — the period from the date the enterprise —

(i)	first acquired; or
(ii)	first chartered, or leased under a finance lease, from a related party,

during the period of approval of the enterprise, a sea‑going ship for use outside the limits of the port of Singapore, to the date where no income of any sea‑going ship of that enterprise is eligible for exemption from tax under subsection (1) (both dates inclusive).”; and

(j)

by inserting, immediately after subsection (20), the following subsection:

“(21) Rules made for the purpose of the definition of “related party” in subsection (20) may be made to take effect from (and including) 12 December 2018.”.

Amendment of section 13X

17. Section 13X of the principal Act is amended —

(a)

by inserting, immediately after the words “feeder fund,” in subsection (1), “SPV,”;

(b)

by deleting the word “and” at the end of subsection (1)(c)(ii);

(c)

by deleting the comma at the end of sub‑paragraph (iii) of subsection (1)(c) and substituting a semi‑colon, and by inserting immediately thereafter the following sub‑paragraphs:

“(iv)	an approved eligible SPV of the structure, where the eligible SPV is not one mentioned in sub‑paragraphs (v), (vi) and (vii);
(v)	a partner of an approved eligible SPV of the structure, where the eligible SPV is a partnership (including a limited partnership and a limited liability partnership);
(vi)	the trustee of an approved eligible SPV of the structure, where the eligible SPV is a trust fund; and
(vii)	the taxable entity of an approved eligible SPV of the structure, where the eligible SPV is not a legal entity,”;

(d)

by deleting the word “and” at the end of subsection (1)(d)(ii);

(e)

by deleting the comma at the end of sub‑paragraph (iii) of subsection (1)(d) and substituting a semi‑colon, and by inserting immediately thereafter the following sub‑paragraphs:

“(iv)	an approved eligible SPV of the structure, where the eligible SPV is not one mentioned in sub‑paragraphs (v), (vi) and (vii);
(v)	a partner of an approved eligible SPV of the structure, where the eligible SPV is a partnership (including a limited partnership and a limited liability partnership);
(vi)	the trustee of an approved eligible SPV of the structure, where the eligible SPV is a trust fund; and
(vii)	the taxable entity of an approved eligible SPV of the structure, where the eligible SPV is not a legal entity,”;

(f)

by deleting the words “31st March 2019” in subsections (2) and (2A) and substituting in each case the words “31st December 2024”;

(g)

by deleting subsection (2B) and substituting the following subsections:

“(2B) Approval under subsection (1)(c)(i) and (d)(i) may be granted during the period from 1 April 2015 to 31 December 2024 (both dates inclusive).

(2C) Approval under subsection (1)(c)(ia), (ib) and (ic) may be granted during the period from 20 February 2018 to 31 December 2024 (both dates inclusive).

(2D) Approval under subsection (1)(c)(ii) and (iii) and (d)(ii) and (iii) may be granted during the period from 1 April 2015 to 18 February 2019 (both dates inclusive).

(2E) Approval under subsection (1)(c)(iv), (v), (vi) and (vii) and (d)(iv), (v), (vi) and (vii) may be granted during the period from 19 February 2019 to 31 December 2024 (both dates inclusive).”;

(h)

by deleting the words “or 2nd tier SPV” in subsections (3) and (4)(a), (b) and (ca) and substituting in each case the words “, 2nd tier SPV or eligible SPV”;

(i)

by inserting, immediately after the definition of “designated unit trust” in subsection (5), the following definition:

“ “eligible SPV”, in relation to a master‑feeder fund‑SPV structure or a master fund‑SPV structure, means a special purpose vehicle where the net gains, profits or other benefits of all investments held by the vehicle are to go (whether directly or indirectly) to the master fund of the structure, or the master fund and one or more of the following:

(a)

a prescribed person under section 13CA;

(b)

an approved company under section 13R;

(c)

an approved person, or an approved master fund, an approved feeder fund, an approved 1st tier SPV, an approved 2nd tier SPV or an approved eligible SPV of any structure mentioned in subsection (1);

(d)

a prescribed sovereign fund entity or an approved foreign government‑owned entity under section 13Y;

(e)

a person (excluding an individual and a Hindu joint family) —

(i)	that is not resident in Singapore;
(ii)	that does not have a permanent establishment in Singapore (other than a fund manager);
(iii)	that does not carry on a business in Singapore;
(iv)	that is not set up solely for the purpose of avoiding or reducing the payment of any tax or penalty under this Act; and
(v)	that carries on outside Singapore substantial business activity for a genuine commercial reason;

(f)

a trust fund —

(i)	the trustee of which is not resident in Singapore or a citizen of Singapore;
(ii)	the trustee of which does not (in its capacity as such trustee) have a permanent establishment in Singapore other than a fund manager for that trust fund;
(iii)	the trustee of which does not carry on any business in Singapore other than acting as such trustee;
(iv)	the trustee of which (in its capacity as such trustee) carries on outside Singapore substantial business activity for a genuine commercial reason; and
(v)	that is not set up solely for the purpose of avoiding or reducing the payment of any tax or penalty under this Act;

(g)

a partnership (including a limited partnership and a limited liability partnership) —

(i)	none of the partners of which is resident in Singapore;
(ii)	that does not have a permanent establishment in Singapore (other than a fund manager);
(iii)	that does not carry on a business in Singapore;
(iv)	that is not set up solely for the purpose of avoiding or reducing the payment of any tax or penalty under this Act; and
(v)	that carries on outside Singapore substantial business activity for a genuine commercial reason;

(h)

an investment vehicle that is not a legal person —

(i)	the taxable entity of which is the custodian of investments held by it;
(ii)	the taxable entity of which is not a resident in Singapore or a citizen of Singapore;
(iii)	the taxable entity of which (in its capacity as custodian of investments held by the investment vehicle) does not have a permanent establishment in Singapore other than a fund manager for that investment vehicle;
(iv)	the taxable entity of which does not carry on any business in Singapore other than acting as such custodian;
(v)	the taxable entity of which carries on outside Singapore substantial business activity for a genuine commercial reason; and
(vi)	that is not set up solely for the purpose of avoiding or reducing the payment of any tax or penalty under this Act;”;

(j)

by deleting the definition of “special purpose vehicle” or “SPV” in subsection (5) and substituting the following definition:

“ “special purpose vehicle” or “SPV” —

(a)	in relation to a master-feeder fund‑SPV structure, means an investment vehicle whose only activity is the holding of investments for other investment vehicles or persons which must include the master and feeder funds of the structure; or
(b)	in relation to a master fund‑SPV structure, means an investment vehicle whose only activity is the holding of investments for other investment vehicles or persons which must include the master fund of the structure;”;

(k)

by deleting the words “and a feeder fund” in the definition of “taxable entity” in subsection (5) and substituting the words “, a feeder fund and an SPV”;

(l)

by deleting the semi‑colon at the end of subsection (6)(b)(iii) and substituting a full‑stop; and

(m)

by deleting paragraph (c) of subsection (6).

Amendment of section 13Y

18. Section 13Y(2) of the principal Act is amended by deleting the words “1st April 2010 and 31st March 2019” and substituting the words “1 April 2010 and 31 December 2024”.

Amendment of section 13Z

19. Section 13Z of the principal Act is amended —

(a)

by deleting the words “or FRS 109” in subsections (6)(d) and (7)(b) and substituting in each case the words “, FRS 109 or SFRS(I) 9”; and

(b)

by deleting the definition of “FRS 109” in subsection (9) and substituting the following definitions:

“ “FRS 109” and “SFRS(I) 9” have the meanings given to those expressions in section 34AA(15).”.

Amendment of section 14V

20. Section 14V of the principal Act is amended —

(a)

by inserting, immediately after “INT FRS 112” in subsection (1)(a)(ii), the words “or SFRS(I) INT 12”;

(b)

by inserting, immediately after “INT FRS 112” in subsection (1)(c), the words “or SFRS(I) INT 12 (as the case may be)”;

(c)

by inserting, immediately after “FRS 38” wherever they appear in subsection (1), the words “or SFRS(I) 1‑38 (as the case may be)”; and

(d)

by deleting subsection (2) and substituting the following subsection:

“(2) In this section —

“FRS 38” and “SFRS(I) 1‑38” mean the financial reporting standards known respectively as —

(a)	Financial Reporting Standard 38 (Intangible Assets); and
(b)	Singapore Financial Reporting Standard (International) 1‑38 (Intangible Assets),

that are made by the Accounting Standards Council under Part III of the Accounting Standards Act, as amended from time to time;

“INT FRS 112” and “SFRS(I) INT 12” have the meanings given to those expressions in section 10F(2).”.

Amendment of section 14ZB

21. Section 14ZB of the principal Act is amended —

(a)

by deleting subsection (1) and substituting the following subsections:

“(1) Subject to this section, where the Comptroller is satisfied that a qualifying person has incurred, during the period between 1 July 2016 and 31 December 2021 (both dates inclusive), qualifying expenditure in respect of —

(a)	the provision during that period by a qualifying employee of the qualifying person, of services that satisfy subsection (2) to an IPC; or
(b)	the secondment during that period of a qualifying employee of the qualifying person to an IPC,

then there is to be allowed to the qualifying person a deduction in accordance with subsection (1A) or (1B), as the case may be.

(1A) Where the qualifying expenditure is salary expenditure, the deduction that the qualifying person is to be allowed is as follows:

(a)

where —

(i)	the expenditure is allowable as a deduction under section 14; and
(ii)	the qualifying person did not opt in the declaration under subsection (6) to compute the expenditure at the prescribed hourly rate,

a further deduction equal to 150% of the endorsed amount of the expenditure in addition to the deduction allowed under section 14;

(b)

where —

(i)	the expenditure is allowable as a deduction under section 14; and
(ii)	the qualifying person opted in the declaration under subsection (6) to compute the expenditure at the prescribed hourly rate,

a further deduction equal to 150% of the computed salary amount in addition to the deduction allowed under section 14;

(c)

where —

(i)	the expenditure is not allowable as a deduction under section 14; and
(ii)	the qualifying person did not opt in the declaration under subsection (6) to compute the expenditure at the prescribed hourly rate,

a deduction equal to 250% of the endorsed amount of the expenditure;

(d)

where —

(i)	the expenditure is not allowable as a deduction under section 14; and
(ii)	the qualifying person opted in the declaration under subsection (6) to compute the expenditure at the prescribed hourly rate,

a deduction equal to 250% of the computed salary amount.

(1B) Where the qualifying expenditure is not salary expenditure, the deduction that the qualifying person is to be allowed is as follows:

(a)	where the expenditure is allowable as a deduction under section 14 — a further deduction equal to 150% of the endorsed amount of the expenditure in addition to the deduction allowed under that section;
(b)	where the expenditure is not allowable as a deduction under section 14 — a deduction equal to 250% of the endorsed amount of the expenditure.”;

(b)

by inserting, immediately after subsection (5), the following subsection:

“(5A) Where a qualifying person opted in a declaration under subsection (6) to compute any salary expenditure at the prescribed hourly rate, then the computed salary amount —

(a)	is treated as the amount of that expenditure incurred by the qualifying person for the purposes of subsections (3) and (5); and
(b)	is to be used in computing the maximum amount of qualifying expenditure for which deductions may be allowed in relation to the IPC in question for the purposes of subsection (4).”;

(c)

by deleting sub-paragraph (ii) of subsection (6)(b) and substituting the following sub‑paragraph:

“(ii)

the relevant details specified in subsection (6A); and”;

(d)

by inserting, immediately after subsection (6), the following subsection:

“(6A) In subsection (6)(b)(ii), the relevant details are —

(a)

where —

(i)	the qualifying expenditure is salary expenditure; and
(ii)	the qualifying person opted in the declaration under subsection (6) to compute the expenditure at the prescribed hourly rate,

the actual number of hours for which the services were provided, as well as the number of those hours (which may be the same number or a smaller number of hours) endorsed by the IPC for the deduction under subsection (1); or

(b)

in all other cases, the amount of the actual qualifying expenditure incurred, as well as the part of that amount (which may be the full amount or a part of it) endorsed by the IPC for the deduction under subsection (1).”;

(e)

by inserting, immediately after the word “expenditure” in subsection (10), the words “or the endorsed number of hours (as the case may be)”;

(f)

by inserting, immediately after subsection (11), the following subsection:

“(11A) Where —

(a)	the qualifying expenditure mentioned in subsection (11) is salary expenditure; and
(b)	the computed salary amount of that expenditure was used to compute the amount of deduction allowed to the qualifying person,

then, for the purpose of that subsection, the amount of the deduction that corresponds to the expenditure reimbursed is to be computed using the formula

where —

(c)	A is the amount of the reimbursement;
(d)	B is the amount of the actual salary expenditure;
(e)	C is the prescribed hourly rate used in computing the computed salary amount; and
(f)	D is the endorsed number of hours used in computing the computed salary amount.”;

(g)

by inserting, immediately after the definition of “central hiring arrangement” in subsection (12), the following definition:

“ “computed salary amount”, in relation to any salary expenditure for the provision of any services by a qualifying employee, means an amount computed using the formula A × B, where —

(a)	A is the endorsed number of hours for those services; and
(b)	B is the prescribed hourly rate for those services;”;

(h)

by deleting the words “subsection (6)(b)” in the definition of “endorsed amount” in subsection (12) and substituting the words “subsection (6A)(b)”;

(i)

by inserting, immediately after the definition of “endorsed amount” in subsection (12), the following definition:

“ “endorsed number of hours”, in relation to any services, means the number of hours for which those services are provided, as endorsed by an IPC under subsection (6A)(a);”;

(j)

by inserting, immediately after the definition of “IPC” in subsection (12), the following definition:

“ “prescribed hourly rate”, in relation to the provision of any services by a qualifying employee, means the rate prescribed by rules made under section 7 for those services;”;

(k)

by deleting the words “under which the employee is required to work for at least 35 hours each week,” in the definition of “qualifying employee” in subsection (12); and

(l)

by deleting “2018” in subsection (13)(b) and substituting “2021”.

New section 14ZD

22.—(1) The principal Act is amended by inserting, immediately after section 14ZC, the following section:

“Deduction for expenditure incurred by individual in deriving commission

14ZD.—(1) This section applies for the purpose of ascertaining, for the basis period for the year of assessment 2020 or a subsequent year of assessment, a qualifying individual’s income by way of commission that is derived from carrying on one or more trades, businesses, professions or vocations that are prescribed by rules made under section 7 (called in this section a prescribed activity or activities), in respect of which there are outgoings or expenses that are deductible under this Part.

(2) Despite any other provision in this Part, there is to be deducted, in lieu of those outgoings or expenses, an amount computed in accordance with the formula A × B, where —

(a)	A is 25% or such other percentage as may be prescribed by rules made under section 7; and
(b)	B is the gross amount of the individual’s commission derived from carrying on a prescribed activity or (if the individual carries on more than one prescribed activity in the basis period) all of those prescribed activities in the basis period, being commission in respect of which there are outgoings or expenses that are deductible under this Part.

(3) However, subsection (2) does not apply to an individual who has made an election under subsection (4) to disapply subsection (2) to the individual’s commission derived from carrying on a prescribed activity or prescribed activities in the basis period.

(4) An individual may, in such form and manner and within such time as the Comptroller may determine, make an election to the Comptroller to disapply subsection (2) to the individual’s commission derived from carrying on a prescribed activity or prescribed activities in the basis period for a particular year of assessment.

(5) If the individual derived commission from carrying on more than one prescribed activity in the basis period in respect of which there are outgoings or expenses that are deductible under this Part, the individual may not make an election under subsection (4) in respect of only one or some of those prescribed activities.

(6) In this section —

“commission” means commission that is chargeable to tax under section 10(1)(a), and includes such other payment as may be prescribed by rules made under section 7, but excludes any commission —

(a)	that is derived by the individual concerned as a partner of a partnership; or
(b)	that is prescribed by rules made under section 7 as not commission;

“qualifying individual”, in relation to any basis period, means an individual who satisfies all of the following conditions:

(a)	the individual is resident in Singapore in the year of assessment relating to the basis period;
(b)	the individual derived commission from a prescribed activity or prescribed activities in the basis period, being commission in respect of which there are outgoings or expenses that are deductible under this Part, and the total amount of such commission does not exceed $50,000 or such amount as may be prescribed by rules made under section 7;
(c)	such other conditions as may be prescribed by rules made under section 7.”.

(2) Subsection (1) has effect for the year of assessment 2020 and subsequent years of assessment.

Amendment of section 19B

23. Section 19B of the principal Act is amended —

(a)

by inserting, immediately after subsection (2B), the following subsections:

“(2BA) If —

(a)	any requirement under subsection (2A)(a) and (b) has been waived (whether before, on or after the date the Income Tax (Amendment) Act 2019 is published in the Gazette) for a company in relation to any writing‑down allowances under subsection (2B); and
(b)	the company fails to comply with a condition subsequent imposed under subsection (2B) for such waiver,

then, if the Minister or the person appointed by the Minister is satisfied, having regard to the company’s representation and all the relevant circumstances of the case, that it is just and reasonable to do so, the Minister or appointed person —

(c)	may make a determination that the company is not entitled to any writing‑down allowance in respect of the relevant intellectual property rights for each year of assessment beginning with a specified year of assessment; and
(d)	must give a written notice of the determination to the Comptroller and the company.

(2BB) If a determination is made under subsection (2BA), then (despite anything in this section) —

(a)

any writing‑down allowance that has already been made to the company in respect of those relevant intellectual property rights for each year of assessment beginning with the specified year of assessment is treated for the purposes of this section as having been wrongly made, and the Comptroller may, subject to section 74, make an assessment or additional assessment on the company for the year or years of assessment to make good any tax shortfall; and

(b)

no writing-down allowance may be made to the company in respect of the relevant intellectual property rights —

(i)	for any year of assessment after the year or years of assessment mentioned in paragraph (a); or
(ii)	if no writing‑down allowance has been made to the company for the specified year of assessment, for the specified year of assessment and each subsequent year of assessment.”; and

(b)

by deleting paragraph (a) of subsection (10) and substituting the following paragraphs:

“(a)	under subsection (1) for any capital expenditure incurred in respect of intellectual property rights acquired after the last day of the basis period for the year of assessment 2016;
(aa)	under subsection (1AA) for any capital expenditure incurred in respect of intellectual property rights acquired after the last day of the basis period for the year of assessment 2025; or”.

Amendment of section 26

24. Section 26 of the principal Act is amended —

(a)

by inserting, immediately after the words “Insurance Act (Cap. 142)” in subsection (3)(b)(i), the words “after deducting any liability in respect of reinsurance ceded to a reinsurer”;

(b)

by inserting, immediately after the words “Insurance Act” in subsection (3)(b)(ii), the words “after deducting any liability in respect of reinsurance ceded to a reinsurer”;

(c)

by inserting, immediately after the words “Insurance Act” in paragraphs (a)(ii) and (b)(iv) of both definitions of “offshore life insurance surplus” in subsection (12), the words “and after deducting any liability in respect of reinsurance ceded to a reinsurer”;

(d)

by inserting, immediately after the words “Insurance Act” in paragraphs (a)(ii) and (b)(iv) of both definitions of “onshore life insurance surplus” in subsection (12), the words “and after deducting any liability in respect of reinsurance ceded to a reinsurer”;

(e)

by inserting, immediately after the words “Insurance Act” in the definition of “policy liabilities” in subsection (12), the words “, but excludes liabilities ceded to a reinsurer”; and

(f)

by inserting, immediately after the definition of “policy moneys” in subsection (12), the following definition:

“ “reinsurer” has the meaning given by section 1A of the Insurance Act;”.

Amendment of section 34C

25. Section 34C of the principal Act is amended —

(a)

by deleting the definitions of “FRS 38” and “FRS 103” in subsection (2) and substituting the following definitions:

“ “FRS 38”, “FRS 103”, “SFRS(I) 1‑38” and “SFRS(I) 3” mean the financial reporting standards known respectively as —

(a)	Financial Reporting Standard 38 (Intangible Assets);
(b)	Financial Reporting Standard 103 (Business Combinations);
(c)	Singapore Financial Reporting Standard (International) 1‑38 (Intangible Assets); and
(d)	Singapore Financial Reporting Standard (International) 3 (Business Combinations),

that are made by the Accounting Standards Council under Part III of the Accounting Standards Act, as amended from time to time;”; and

(b)

by inserting, immediately after the words “FRS 38 and FRS 103” in subsection (20), the words “, or with SFRS(I) 1‑38 and SFRS(I) 3,”.

Amendment of section 34G

26. Section 34G of the principal Act is amended —

(a)

by deleting the definition of “FRS 109” in subsection (2) and substituting the following definitions:

“ “FRS 109” and “SFRS(I) 9” have the meanings given to those expressions in section 34AA(15);”; and

(b)

by inserting, immediately after “FRS 109” in subsection (5)(a), the words “or SFRS(I) 9, as the case may be”.

New section 34J

27. The principal Act is amended by inserting, immediately after section 34I, the following section:

“Tax treatment arising from adoption of FRS 116 or SFRS(I) 16

34J.—(1) Where an MSI recipient (called in this section an electing recipient) makes an election in accordance with subsection (10) to adopt the tax treatment under this section, then, despite any other provision of this Act, that tax treatment applies in relation to the electing recipient in accordance with this section.

(2) If, in any applicable period, a sublease by the electing recipient of a sublease asset is recognised by the electing recipient as a finance lease in accordance with FRS 116 or SFRS(I) 16, any income of the electing recipient derived under that sublease in that applicable period is taken as having been derived from a finance lease for the purpose of section 10D.

(3) If, in any applicable period, a sublease by the electing recipient of a sublease asset is recognised by the electing recipient as an operating lease in accordance with FRS 116 or SFRS(I) 16, any income of the electing recipient derived under that sublease in that applicable period is taken as not having been derived from a finance lease for the purpose of section 10D.

(4) The electing recipient is not entitled to any deduction under Part V in a year of assessment for any outgoing or expense incurred during an applicable period in relation to a qualifying asset of which it is a lessee, against any income derived by it from any use of that qualifying asset.

(5) Where the electing recipient makes an election under subsection (10) at the time of lodgment of the return of income for the year of assessment for the basis period in which 12 December 2018 falls, then —

(a)

for the year of assessment for the basis period in which that date falls — the capital allowances to be made to it under section 19, 19A or 22 for any qualifying asset of which it is a lessee, are to be reduced by an amount computed by the formula

where —

(i)	A is the number of days between 12 December 2018 and the last day of the basis period for that year of assessment (both days inclusive); and
(ii)	B is the amount of the capital allowances for that year of assessment for that qualifying asset;

(b)

for the year of assessment for the basis period in which that date falls — no allowance may be made to, and no charge may be made on, the electing recipient under section 20 or 21 for any event mentioned in section 20(1) that occurs in the period between 12 December 2018 and the last day of the basis period for that year of assessment (both days inclusive), in relation to any qualifying asset of which it is a lessee; and

(c)

for any subsequent year of assessment other than the last year of assessment —

(i)	the electing recipient is not entitled to any allowance under section 19, 19A or 22; and
(ii)	no allowance may be made to, and no charge may be made on, the electing recipient under section 20 or 21 for any event mentioned in section 20(1) that occurs in the basis period for that year of assessment,

in relation to any qualifying asset of which it is a lessee.

(6) Where the electing recipient makes the election under subsection (10) at the time of lodgment of the return of income for the year of assessment for any basis period other than that in which 12 December 2018 falls, then, for every year of assessment beginning with the basis period in which it makes the election and before the last year of assessment —

(a)	the electing recipient is not entitled to any allowance under section 19, 19A or 22; and
(b)	no allowance may be made to, and no charge may be made on, the electing recipient under section 20 or 21 for any event mentioned in section 20(1) that occurs in the basis period for that year of assessment,

in relation to any qualifying asset of which it is a lessee.

(7) For the last year of assessment, the capital allowances under section 19, 19A or 22 for any qualifying asset of which the electing recipient is a lessee, and which was leased for its trade or business before the date it ceases to be an MSI recipient, are to be —

(a)

computed on the residue of the capital expenditure or reducing value of the qualifying asset (as the case may be) after deducting all such allowances (including initial and annual allowances) that have or would (but for subsection (5) or (6)) have been made to the electing recipient for all past years of assessment, even if no such allowance was made; and

(b)

reduced by an amount computed by the formula

where —

(i)	A is the number of days between the first day of the basis period of the last year of assessment and the day before the day the electing recipient ceases to be an MSI recipient (both days inclusive); and
(ii)	B is the amount of the capital allowances for the last year of assessment as computed in accordance with paragraph (a).

(8) For the last year of assessment, no allowance may be made to, and no charge may be made on, the electing recipient under section 20 or 21 for any event mentioned in section 20(1) that occurs between the first day of the basis period of that year of assessment and the day before the day it ceases to be an MSI recipient (both days inclusive), in relation to any qualifying asset of which it is a lessee.

(9) For each subsequent year of assessment after the last year of assessment, the capital allowances under section 19, 19A or 22 for any qualifying asset of which the electing recipient is a lessee, and which was leased for its trade or business before the day it ceases to be an MSI recipient, are to be computed on the residue of the capital expenditure or reducing value of the qualifying asset (as the case may be) after deducting —

(a)	all such allowances (including initial and annual allowances) that have or would (but for subsection (5) or (6)) have been made to the electing recipient for all past years of assessment, even if no such allowance was made; and
(b)	the total amount of such allowances that would have been made to the electing recipient for the last year of assessment without the reduction under subsection (7)(b).

(10) An MSI recipient may make an election to adopt the tax treatment under this section by providing a written notice to the Comptroller of this —

(a)	at the time of lodgment of the return of income for the year of assessment relating to a basis period during which its financial accounts are prepared in accordance with FRS 116 or SFRS(I) 16; or
(b)	within such further time as the Comptroller may allow.

(11) An election made under subsection (10) is irrevocable.

(12) If —

(a)	the tax treatment under this section has been applied in relation to a ship that is provisionally registered under the Merchant Shipping Act (Cap. 179), and that is operated by an electing recipient that is a shipping enterprise (called in this subsection and subsection (13) the provisionally‑registered ship); and
(b)	the electing recipient subsequently fails to obtain a permanent certificate of registry under that Act in respect of that ship,

then the Comptroller must, in relation to every year of assessment for which the tax treatment under this section has already been applied in relation to the provisionally‑registered ship —

(c)	make an assessment or additional assessment under section 74 on the electing recipient; or
(d)	revise an assessment already made and give a refund to the electing recipient for any tax overpaid,

as the case may be, as if the tax treatment had not been applied for that year of assessment in relation to both the provisionally‑registered ship and relevant assets.

(13) In subsection (12), “relevant assets” means —

(a)	if, at the end of the basis period for the year of assessment mentioned in that subsection, the electing recipient operates only the provisionally‑registered ship and no other Singapore ship, all sublease assets and qualifying assets of the electing recipient; or
(b)	if, at the end of the basis period for the year of assessment mentioned in that subsection, the electing recipient operates one or more other Singapore ships in addition to the provisionally‑registered ship, any on‑board equipment integral to the operation of the provisionally‑registered ship but no other ship.

(14) In this section —

“applicable period” means —

(a)

the later of the following:

(i)	the period between 12 December 2018 and the last day of the basis period in which that date falls (both days inclusive);
(ii)	the basis period in which the electing recipient makes the election under subsection (10);

(b)

each basis period that is subsequent to the period mentioned in paragraph (a) and before the period mentioned in paragraph (c); or

(c)

the period starting on the first day of the basis period in which the electing recipient ceases to be an MSI recipient, and ending on (and including) the day before the day of such cessation;

“approved container investment enterprise” means an approved container investment enterprise mentioned in section 43ZA;

“approved international shipping enterprise” means an approved international shipping enterprise mentioned in section 13F;

“approved shipping investment enterprise” means an approved shipping investment enterprise mentioned in section 13S;

“container” has the meaning given by section 43ZA(7);

“FRS 116” means the financial reporting standard issued by the Accounting Standards Council under Part III of the Accounting Standards Act and known as Financial Reporting Standard 116 (Leases);

“intermodal equipment” has the meaning given by section 43ZA(7);

“last year of assessment” means the year of assessment for the basis period in which the electing recipient ceases to be an MSI recipient;

“Maritime Sector Incentive recipient” or “MSI recipient” means a shipping enterprise, an approved international shipping enterprise, an approved shipping investment enterprise, or an approved container investment enterprise;

“qualifying asset” means —

(a)

in the case of an electing recipient that is a shipping enterprise, any of the following:

(i)	any Singapore ship;
(ii)	any on-board equipment integral to the operation of Singapore ships;
(iii)	any container;
(iv)	any intermodal equipment or any other equipment integral to the operation of containers;

(b)

in the case of an electing recipient that is an approved international shipping enterprise, any of the following:

(i)	any ship;
(ii)	any on-board equipment integral to the operation of ships;
(iii)	any container;
(iv)	any intermodal equipment or any other equipment integral to the operation of containers;

(c)

in the case of an electing recipient that is an approved shipping investment enterprise, any of the following:

(i)	any ship;
(ii)	any on-board equipment integral to the operation of ships; and

(d)

in the case of an electing recipient that is an approved container investment enterprise, any of the following:

(i)	any container;
(ii)	any intermodal equipment or any other equipment integral to the operation of containers,

but excludes anything that is used solely in the basis period concerned to derive income that is not income that is subject to exemption or a concessionary rate of tax under section 13A, 13F, 13S or 43ZA;

“SFRS(I) 16” means the financial reporting standard issued by the Accounting Standards Council under Part III of the Accounting Standards Act and known as Singapore Financial Reporting Standard (International) 16 (Leases);

“ship” has the meaning given by section 2(1) of the Merchant Shipping Act;

“shipping enterprise” means a company that owns or operates one or more Singapore ships;

“Singapore ship” means —

(a)	a ship in respect of which a permanent certificate of registry has been issued under the Merchant Shipping Act and whose registry is not closed or deemed to be closed or suspended; or
(b)	a ship that is provisionally registered under that Act;

“sublease asset” means —

(a)	in the case of an electing recipient that is a shipping enterprise, any Singapore ship or container;
(b)	in the case of an electing recipient that is an approved international shipping enterprise, any ship or container;
(c)	in the case of an electing recipient that is an approved shipping investment enterprise, any ship; and
(d)	in the case of an electing recipient that is an approved container investment enterprise, any container or intermodal equipment,

Amendment of section 37L

28. Section 37L of the principal Act is amended —

(a)

by deleting the words “FRS 28, or SFRS for Small Entities, as amended from time to time” in subsection (16E) and substituting the words “FRS 28, SFRS(I) 1‑28, or SFRS for Small Entities”;

(b)

by deleting subsection (16F) and substituting the following subsection:

“(16F) In subsection (16E), “FRS 28”, “SFRS(I) 1‑28” and “SFRS for Small Entities” mean the financial reporting standards known respectively as —

(a)	Financial Reporting Standard 28 (Investments in Associates and Joint Ventures);
(b)	Singapore Financial Reporting Standard (International) 1‑28 (Investments in Associates and Joint Ventures); and
(c)	Singapore Financial Reporting Standard for Small Entities,

that are made by the Accounting Standards Council under Part III of the Accounting Standards Act, as amended from time to time.”; and

(c)

by inserting, immediately after subsection (19A), the following subsections:

“(19B) If —

(a)	any requirement under subsections (16A)(d) and (17)(e) has been waived (whether before, on or after the date the Income Tax (Amendment) Act 2019 is published in the Gazette) for an acquiring company in respect of any qualifying acquisition under subsection (19A); and
(b)	the acquiring company fails to comply with a condition subsequent imposed under subsection (19A) for such waiver,

then, if the Minister or the person appointed by the Minister is satisfied, having regard to the acquiring company’s representation and all the relevant circumstances of the case, that it is just and reasonable to do so, the Minister or appointed person —

(c)	may make a determination that the company is not entitled to any deduction in respect of the qualifying acquisition for each year of assessment beginning with a specified year of assessment; and
(d)	must give a written notice of the determination to the Comptroller and the company.

(19C) If a determination has been made under subsection (19B), then (despite anything in this section) —

(a)

any deduction that has already been made to the acquiring company in respect of the qualifying acquisition for each year of assessment beginning with the specified year of assessment is treated for the purposes of this section as having been wrongly allowed, and the Comptroller may, subject to section 74, make an assessment or additional assessment on the company for those years of assessment to make good any tax shortfall; and

(b)

no deduction may be made to the company for the qualifying acquisition —

(i)	for any year of assessment after the year or years of assessment mentioned in paragraph (a); or
(ii)	if no deduction has been made to the company for the specified year of assessment, for the specified year of assessment and each subsequent year of assessment.”.

Amendment of section 39

29.—(1) Section 39 of the principal Act is amended —

(a)

by deleting the words “an unmarried child” in subsection (2)(e) and substituting the words “a child who was unmarried throughout the year preceding the year of assessment and”;

(b)

by deleting sub-paragraph (ii) of subsection (2)(p) and substituting the following sub‑paragraph:

“(ii)

was looking after any of her children who is a citizen of Singapore and —

(A)	was 12 years old and below at any time during the year preceding the year of assessment; or
(B)	was unmarried throughout the year preceding the year of assessment, and also incapacitated by reason of physical or mental infirmity; and”;

(c)

by deleting the words “there shall be allowed against her earned income a deduction of $3,000 in respect of one such parent or grandparent only:” in subsection (2)(p) and the proviso and substituting the following:

“there shall be allowed against her earned income a deduction of $3,000 in respect of one such parent or grandparent only, except that —

“(iv)	a deduction under this paragraph in respect of that parent or grandparent may be allowed to one woman only; and
(v)	where more than one woman claims a deduction under this paragraph in respect of the same parent or grandparent, a deduction may be allowed to such claimant as the women may agree or (failing such agreement) to such claimant as determined by the Comptroller whose decision is final;”; and

(d)

by inserting, immediately after subsection (2), the following subsection:

“(2AA) In subsection (2)(p), “child” has the meaning given by paragraph 7 of the Fifth Schedule.”.

(2) Subsection (1)(b), (c) and (d) has effect for the year of assessment 2020 and subsequent years of assessment.

Amendment of section 43

30. Section 43 of the principal Act is amended —

(a)

by deleting the words “March 2020” in subsections (2A)(ba), (3B) and (3C)(b) and substituting in each case the words “December 2025”; and

(b)

by inserting, immediately after subsection (3C), the following subsections:

“(3D) In the application of subsection (3B) to a distribution mentioned in that subsection made during the period from 1 July 2019 to 31 December 2025 (both dates inclusive) to a person mentioned in subsection (3F) with a fund manager in Singapore, that fund manager is not considered a permanent establishment in Singapore of that person.

(3E) In the application of subsection (3C) to a distribution mentioned in that subsection made during the period from 1 July 2019 to 31 December 2025 (both dates inclusive) to a person mentioned in subsection (3F) with a fund manager in Singapore, that fund manager is not considered a permanent establishment in Singapore of that person.

(3F) Subsection (3D) or (3E) applies to a distribution made to any of the following persons or entities that is not resident in Singapore:

(a)	a prescribed person (other than an individual) under section 13CA;
(b)	an approved person under section 13X;
(c)	a person (not being an individual, a body of persons or a Hindu joint family) that is the approved master fund or an approved feeder fund of an approved master‑feeder fund structure under section 13X;
(d)	a partner of a partnership (including a limited partnership and a limited liability partnership), where the partnership is the approved master fund or an approved feeder fund of an approved master‑feeder fund structure under section 13X;
(e)	a trustee of a trust fund where the trust fund is the approved master fund or an approved feeder fund of an approved master‑feeder fund structure under section 13X;
(f)	a taxable entity in relation to the approved master fund or an approved feeder fund of an approved master‑feeder fund structure under section 13X, where the master fund or feeder fund is not a legal entity;
(g)	a company, a trustee of a trust fund or a partner of a limited partnership, where the company, trust fund or limited partnership is an approved feeder fund of an approved master‑feeder fund‑SPV structure under section 13X;
(h)	a person (not being a company, an individual or a Hindu joint family) that is an approved feeder fund of an approved master‑feeder fund‑SPV structure under section 13X;
(i)	a partner of a partnership (excluding a limited partnership but including a limited liability partnership), where the partnership is an approved feeder fund of an approved master‑feeder fund‑SPV structure under section 13X;
(j)	a taxable entity in relation to an approved feeder fund of an approved master‑feeder fund‑SPV structure under section 13X, where the feeder fund is not a legal entity;
(k)	an approved 1st tier SPV of an approved master‑feeder fund‑SPV structure under section 13X;
(l)	an approved 2nd tier SPV of an approved master‑feeder fund‑SPV structure under section 13X;
(m)	an approved eligible SPV of an approved master‑feeder fund‑SPV structure under section 13X, where the eligible SPV is not one mentioned in paragraphs (n), (o) and (p);
(n)	a partner of an approved eligible SPV of an approved master‑feeder fund‑SPV structure under section 13X, where the eligible SPV is a partnership (including a limited partnership and a limited liability partnership);
(o)	the trustee of an approved eligible SPV of an approved master‑feeder fund‑SPV structure under section 13X, where the eligible SPV is a trust fund;
(p)	the taxable entity of an approved eligible SPV of an approved master‑feeder fund‑SPV structure under section 13X, where the eligible SPV is not a legal entity;
(q)	an approved 1st tier SPV of an approved master fund‑SPV structure under section 13X;
(r)	an approved 2nd tier SPV of an approved master fund‑SPV structure under section 13X;
(s)	an approved eligible SPV of an approved master fund‑SPV structure under section 13X, where the eligible SPV is not one mentioned in paragraphs (t), (u) and (v);
(t)	a partner of an approved eligible SPV of an approved master fund‑SPV structure under section 13X, where the eligible SPV is a partnership (including a limited partnership and a limited liability partnership);
(u)	the trustee of an approved eligible SPV of an approved master fund‑SPV structure under section 13X, where the eligible SPV is a trust fund;
(v)	the taxable entity of an approved eligible SPV of an approved master fund‑SPV structure under section 13X, where the eligible SPV is not a legal entity;
(w)	a prescribed sovereign fund entity or an approved foreign government‑owned entity under section 13Y.”.

Amendment of section 43A

31. Section 43A(2) of the principal Act is amended by inserting, immediately after “FRS 109” in paragraph (d), the words “or SFRS(I) 9”.

Amendment of section 43C

32. Section 43C(1) of the principal Act is amended —

(a)

by inserting, immediately after the word “derived” in paragraph (a), the words “before 1 July 2021”; and

(b)

by inserting, immediately after paragraph (aa), the following paragraph:

“(ab)

to provide for tax at the rate of 10% to be levied and paid for each year of assessment upon such income as the Minister may specify that is derived on or after 1 July 2021 by an approved insurer whose approval is granted before 1 June 2017, from —

(i)	the reinsurance of liabilities under policies relating to life business as defined in section 2(1)(a) of the Insurance Act; or
(ii)	such description of general business as defined in section 2(1)(b) of that Act, as may be prescribed;”.

Amendment of section 43N

33. Section 43N(4) of the principal Act is amended by deleting the definition of “primary dealer” and substituting the following definition:

“ “primary dealer” means any financial institution appointed by the Monetary Authority of Singapore as a primary dealer under section 29A of the Government Securities Act (Cap. 121A);”.

Amendment of section 43ZA

34. Section 43ZA of the principal Act is amended —

(a)

by deleting the word “and” at the end of subsection (1)(c);

(b)

by deleting the full-stop at the end of paragraph (d) of subsection (1) and substituting a semi‑colon, and by inserting immediately thereafter the following paragraphs:

“(e)

the leasing of any container used for international transportation of goods, if the container was —

(i)	acquired by an approved related party before or during the period of the approval of the related party under subsection (4); and
(ii)	leased by the approved related party to the approved container investment enterprise;

(f)

the leasing of any intermodal equipment that is incidental to the lease mentioned in paragraph (e), if the intermodal equipment was —

(i)	acquired by an approved related party before or during the period of the approval of the related party under subsection (4); and
(ii)	leased by the approved related party to the approved container investment enterprise; and

(g)

foreign exchange and risk management activities that are carried out in connection with and incidental to the leases mentioned in paragraphs (e) and (f).”;

(c)

by inserting, immediately after subsection (1), the following subsection:

“(1A) Subsection (1)(e), (f) and (g) only applies to income derived on or after 12 December 2018.”;

(d)

by deleting the words “Subsection (1)” in subsection (2) and substituting the words “Subsection (1)(a), (b), (c) or (d)”;

(e)

by deleting the words “referred to in subsection (1)” in subsection (2) and substituting the words “mentioned in that provision”;

(f)

by inserting, immediately after subsection (2), the following subsections:

“(2A) Subsection (1)(e), (f) or (g) continues to apply to a container investment enterprise the approval of which has expired or been withdrawn, but that continues to derive income of the type mentioned in that provision if both the container investment enterprise and the approved related party have by the date of the expiry or before the withdrawal, fulfilled all the conditions of their respective approvals under subsection (4).

(2B) For the purpose of subsection (2A), the container investment enterprise is treated under this section as an approved container investment enterprise.

(2C) Subsection (1)(a), (c), (e) and (f) does not apply to income derived on or after 12 December 2018 from the leasing of a container or intermodal equipment that is acquired by the approved container investment enterprise or the approved related party by way of a finance lease entered into with an entity that is not an approved related party.”;

(g)

by inserting, immediately after the words “container investment enterprise” in subsection (3), the words “or a related party of an approved container investment enterprise”;

(h)

by deleting the full-stop at the end of the definition of “registered business trust” in subsection (7) and substituting a semi‑colon, and by inserting immediately thereafter the following definition:

“ “related party”, in relation to an approved container investment enterprise, means any entity that is related to the approved container investment enterprise in such manner as may be prescribed by rules made under section 7.”; and

(i)

by inserting, immediately after subsection (7), the following subsection:

“(8) Rules made for the purpose of the definition of “related party” in subsection (7) may be made to take effect from (and including) 12 December 2018.”.

Amendment of section 45AA

35. Section 45AA of the principal Act is amended —

(a)

by deleting subsection (1) and substituting the following subsections:

“(1) Subsection (1A) applies where a notification has been made under section 13(4) to exempt from tax (wholly or in part) payments made by a person to a non‑resident person under section 45 or 45A, and —

(a)	the exemption is on the basis that the firstmentioned person or a particular matter is approved by the Minister or a person appointed by the Minister under a section specified in the Fourth Schedule, and the approval is revoked under section 105R after any such payment has been made; or
(b)	the firstmentioned person contravenes any condition imposed by the Minister under the notification (whether a condition precedent or a condition subsequent) after any such payment has been made.

(1A) The amount of tax which, but for —

(a)	in the case of subsection (1)(a) — the approval of the firstmentioned person or the matter; or
(b)	in the case of subsection (1)(b) — the notification,

would have been deductible by the firstmentioned person from that payment —

(c)	is deemed to have been deducted from that payment;
(d)	is a debt due from the firstmentioned person to the Government; and
(e)	is recoverable in the manner provided in section 89.”; and

(b)

by deleting the words “subsection (1)” in subsections (2), (4) and (7) and substituting in each case the words “subsection (1A)”.

Amendment of section 45G

36. Section 45G of the principal Act is amended —

(a)	by inserting, immediately after the words “section 43(3B)” in subsection (1)(a), the words “, (3C), (3D) or (3E)”; and
(b)	by deleting the words “March 2020” in subsections (2)(a) and (b) and (5) and substituting in each case the words “December 2025”.

New section 45J

37. The principal Act is amended by inserting, immediately after section 45I, the following section:

“Application of section 45, etc., to Government

45J.—(1) Subject to the modifications in subsection (2), sections 45, 45A, 45F and 45GA apply to the payment of any income described in those sections that is liable to be made by the Government to a person not known to the Government to be resident in Singapore, as they apply to the payment of such income liable to be made by a person to another person not known to the firstmentioned person to be resident in Singapore.

(2) The modifications are —

(a)	any amount deducted by the Government under section 45, 45A, 45F or 45GA does not constitute a debt due to the Government and is not recoverable in the manner provided by section 89; and
(b)	section 45(3), (4), (5), (6) and (7) (including those provisions as applied by sections 45A, 45F and 45GA) does not apply.”.

Amendment of section 83

38. Section 83 of the principal Act is amended —

(a)	by deleting the words “and in appeals to, or in cases stated for the opinion of, the High Court under the provisions of this Part, and in appeals from decisions of the High Court under section 81(5)” in subsection (1);
(b)	by deleting the words “or the High Court, as the case may be,” in subsection (2);
(c)	by deleting the words “or the Court” in subsections (2) and (3);
(d)	by deleting the words “or the High Court” in subsection (3); and
(e)	by deleting the words “and High Court” in the section heading.

Amendment of section 101

39. Section 101(2) of the principal Act is amended by inserting, immediately after the word “sections”, “34F(8),”.

New sections 105R and 105S

40. The principal Act is amended by inserting, immediately before section 106 in Part XXI, the following sections:

“Revocation of approval

105R.—(1) This section applies where —

(a)

either —

(i)	a person is approved by the Minister or a person appointed by the Minister (called in this section the approving authority) under a prescribed section for a tax incentive to be applied to the person’s income under that provision or regulations made under that provision; or
(ii)	a matter is approved by an approving authority under a prescribed section for a tax incentive to be applied to a person’s income under that provision or regulations made under that provision; and

(b)

the person fails to comply with a condition of the approval.

(2) The approving authority may, by written notice, require the person to show cause, within 30 days after the date the notice is served on the person or such longer period as the approving authority may permit in a particular case, why the approval should not be revoked.

(3) If the approving authority is satisfied, having regard to the person’s representation and all the relevant circumstances of the case, that it is just and reasonable to do so, the approving authority may revoke the approval, and the revocation is effective from a date specified by the approving authority to the person.

(4) The approving authority may specify any date for the revocation to take effect, including (if it is just and reasonable to do so) —

(a)	a date before the date of the non-compliance with the condition; or
(b)	if the condition is to be complied with over a period of time, before the date of commencement of that period.

(5) The revocation of an approval under this section does not affect the operation of any provision of this Act providing for other consequences for a breach of a condition of the approval.

(6) To avoid doubt, where —

(a)	a tax incentive has been applied to any income of the person under a prescribed section, or an order under section 13(12);
(b)	the tax incentive would not have been applied to the person’s income if the person or matter were not an approved person or matter under the prescribed section on the date the relevant income accrued to or was derived or received by the person, or the relevant expenditure was incurred by the person, as the case may be; and
(c)	the approval is revoked under this section with effect from or before that date,

the Comptroller may make an assessment or additional assessment under section 74 on the person.

(7) This section applies to an approval given under a prescribed section whether before, on or after the date the Income Tax (Amendment) Act 2019 is published in the Gazette.

(8) In this section —

(a)

a prescribed section is a section of the Act specified in the Fourth Schedule;

(b)

a tax incentive is any of the following:

(i)	an exemption from tax;
(ii)	a concessionary rate of tax;
(iii)	a deduction or an allowance;
(iv)	a reduction of the statutory income of a person;

(c)

a tax incentive that is an exemption from tax is applied to a person’s income if any income of the person becomes exempt from tax;

(d)

a tax incentive that is a concessionary rate of tax is applied to a person’s income if tax is levied on any income of the person at that rate;

(e)

a tax incentive that is a deduction or an allowance is applied to a person’s income if it is allowed or made for any expenditure in ascertaining the person’s chargeable income; and

(f)

a tax incentive that is a reduction of the statutory income of a person is applied to a person’s income if such reduction is made to the person’s statutory income.

Conditions for application of tax incentive treated as conditions of approval

105S.—(1) This section applies to each of the following approvals made before the date the Income Tax (Amendment) Act 2019 is published in the Gazette:

(a)	an approval of a Finance and Treasury Centre of a company under section 43G for tax at a concessionary rate to be levied on the company’s income under regulations made under that section;
(b)	an approval of a person under section 43P, 43Q, 43R, 43W, 43Y, 43Z, 43ZB, 43ZC or 43ZD, for tax at a concessionary rate to be levied on the person’s income under that section or regulations made under that section, as the case may be.

(2) For the purposes of section 105R, every condition imposed or specified before the date mentioned in subsection (1) under section 43G(2), 43P(2), 43Q(2), 43R(2), 43W(3), 43Y(2), 43Z(3), 43ZB(3), 43ZC(3) or 43ZD(3) as in force immediately before that date, in relation to a Finance and Treasury Centre or person, is treated as a condition imposed on the approval of the Finance and Treasury Centre or person (as the case may be) under the corresponding section mentioned in subsection (1).

(3) In this section, “Finance and Treasury Centre” has the same meaning as in section 43G.”.

Amendment of section 106

41. Section 106(3) of the principal Act is amended by inserting, immediately after the word “First,”, the word “Fourth,”.

New Fourth Schedule

42. The principal Act is amended by inserting, immediately before the Fifth Schedule, the following Schedule:

“FOURTH SCHEDULE

Sections 45AA(1)(a), 105R(8)(a)
and 106(3)

Prescribed sections

Sections 13F, 13H, 13P, 13S, 13U, 14E, 37K, 43C, 43G, 43J, 43P, 43Q, 43R, 43W, 43Y, 43Z, 43ZA, 43ZB, 43ZC, 43ZD, 43ZF, 43ZG, 43ZH and 43ZI.”.

Miscellaneous amendments relating to new sections 105R and 105S

43.—(1) Section 43G of the principal Act is amended —

(a)

by inserting the word “and” at the end of subsection (2)(a);

(b)

by deleting the word “; and” at the end of subsection (2)(b) and substituting a full‑stop;

(c)

by deleting paragraph (c) of subsection (2); and

(d)

by inserting, immediately after subsection (2), the following subsection:

“(2A) The Minister or a person appointed by the Minister may, subject to such conditions as the Minister or person may impose, approve a Finance and Treasury Centre for a company for the purposes of this section.”.

(2) Section 43N(4) of the principal Act is amended by deleting the definition of “financial sector incentive (standard tier) company” and substituting the following definition:

“ “financial sector incentive (standard tier) company” means a company approved as such under section 43Q;”.

(3) Section 43P of the principal Act is amended —

(a)

by inserting, immediately after subsection (1), the following subsections:

“(1AA) Subject to the regulations under subsection (1), the income of an approved global trading company or approved qualifying company mentioned in that subsection —

(a)	is chargeable with tax at the rate of 5% if the company has been approved for that rate; or
(b)	is chargeable with tax at the rate of 10% if the company has been approved for that rate.

(1AB) For the purposes of this section, the Minister or a person appointed by the Minister may, subject to such conditions as the Minister or person may impose, approve —

(a)	a global trading company as an approved global trading company; or
(b)	a qualifying company as an approved qualifying company.”;

(b)

by deleting subsection (2); and

(c)

by deleting the definition of “approved” in subsection (3).

(4) Section 43Q of the principal Act is amended —

(a)

by deleting subsection (2) and substituting the following subsection:

“(2) The Minister or a person appointed by the Minister may, subject to such conditions as the Minister or person may impose, approve a company carrying on such qualifying activities as may be prescribed, as a financial sector incentive company for the purposes of this section, and the Minister or person may approve different classes of financial sector incentive companies for the purposes of this section.”; and

(b)

by deleting subsection (3).

(5) Section 43R of the principal Act is amended —

(a)

by deleting subsection (2) and substituting the following subsection:

“(2) The Minister or a person appointed by the Minister may, subject to such conditions as the Minister or person may impose, approve a company as an approved company for the purposes of this section.”; and

(b)

by deleting subsection (5).

(6) Section 43W of the principal Act is amended by deleting subsection (3) and substituting the following subsection:

“(3) The Minister or a person appointed by the Minister may, subject to such conditions as the Minister or person may impose, approve a shipping investment manager as an approved shipping investment manager for the purposes of this section.”.

(7) Section 43Y of the principal Act is amended —

(a)

by deleting subsection (2) and substituting the following subsection:

“(2) The Minister or a person appointed by the Minister may, subject to such conditions as the Minister or person may impose, approve an aircraft leasing company as an approved aircraft leasing company for the purposes of this section.”; and

(b)

by deleting the definition of “approved” in subsection (7).

(8) Section 43Z of the principal Act is amended by deleting subsection (3) and substituting the following subsection:

“(3) The Minister or a person appointed by the Minister may, subject to such conditions as the Minister or person may impose, approve an aircraft investment manager as an approved aircraft investment manager for the purposes of this section.”.

(9) Section 43ZB of the principal Act is amended by deleting subsection (3) and substituting the following subsection:

“(3) The Minister or a person appointed by the Minister may, subject to such conditions as the Minister or person may impose, approve a container investment manager as an approved container investment manager for the purposes of this section.”.

(10) Section 43ZC of the principal Act is amended —

(a)

by deleting subsection (3) and substituting the following subsection:

“(3) The Minister or a person appointed by the Minister may, subject to such conditions as the Minister or person may impose, approve a company that is a direct insurance broker, general reinsurance broker or life reinsurance broker, as an approved insurance broker for the purposes of this section.”; and

(b)

by deleting the definition of “approved insurance broker” in subsection (5).

(11) Section 43ZD of the principal Act is amended —

(a)

by deleting subsection (3) and substituting the following subsection:

“(3) For the purposes of this section, the Minister or a person appointed by the Minister may, subject to such conditions as the Minister or person may impose —

(a)	approve a trustee‑manager of a qualifying registered business trust as an approved trustee‑manager; or
(b)	approve a fund management company as an approved fund management company.”; and

(b)

by deleting the definition of “approved” in subsection (5).

Repeal of obsolete provisions

44. The principal Act is amended —

(a)

by deleting the definition of “securities” in section 10(23) and substituting the following definition:

“ “securities” means —

(a)	debentures, stocks, shares, bonds or notes issued by a government of company;
(b)	any right or option in respect of any such debentures, stocks, shares, bonds or notes; or
(c)	units in any unit trust within the meaning of section 10B;”;

(b)

by repealing section 10A;

(c)

by deleting the words “section 10A” in the definition of “securities” in section 10B(2) and substituting the words “section 10(23)”;

(d)

by deleting subsections (4) and (5) of section 10C;

(e)

by deleting the words “Subsections (4) and (5A)” in section 10C(6) and substituting the words “Subsection (5A)”;

(f)

by deleting sub‑paragraph (i) of section 13(1)(aa);

(g)

by deleting paragraphs (jc), (o) and (zn) of section 13(1);

(h)

by deleting paragraphs (f) and (fa) of section 14(1);

(i)

by deleting subsection (1A) of section 14;

(j)

by deleting the words “subsection (1)(f) or (fb), as the case may be,” in the definition of “general contribution” in section 14(8) and substituting the words “subsection (1)(fb)”;

(k)

by deleting the words “subsection (1)(f) or (fb), as the case may be” in paragraph (e) of the definition of “medical expenses” in section 14(8) and substituting the words “subsection (1)(fb)”;

(l)

by deleting the words “any investment company which has been approved under section 10A or” in section 14F(3);

(m)

by deleting subsection (6) of section 14Q;

(n)

by inserting the word “or” at the end of section 14Q(7)(b);

(o)

by deleting paragraphs (c), (d) and (e) of section 14Q(7);

(p)

by deleting the words “subsection (7)(c) to (f)” in section 14Q(8) and substituting the words “subsection (7)(f)”;

(q)

by deleting the words “Subsection (7)(c) to (f)” in section 14Q(8A) and substituting the words “Subsection (7)(f)”;

(r)

by deleting “(f), (fa),” in section 15(1)(i)(iv);

(s)

by deleting subsection (13B) of section 19A;

(t)

by deleting the words “subsections (10A), (13A) and (13B)” in section 19A(14) and substituting the words “subsections (10A) and (13A)”;

(u)

by deleting paragraph (a) of section 26A(2A);

(v)

by deleting the words “for the purposes of every subsequent year of assessment,” in section 26A(2A)(b);

(w)

by deleting “, (13B)” in section 34G(15)(d);

(x)

by deleting the words “section 10A” in the definition of “securities” in section 35(14) and substituting the words “section 10(23)”;

(y)

by inserting the word “and” at the end of section 37C(15)(c);

(z)

by deleting the semi‑colon at the end of section 37C(15)(d) and substituting a full‑stop;

(za)

by deleting paragraphs (e) and (f) of section 37C(15);

(zb)

by deleting the definition of “qualifying start‑up company” in section 37C(19);

(zc)

by repealing section 37H;

(zd)

by deleting paragraph (f) of section 39(2) (including the paragraph heading);

(ze)

by deleting the words “from 1st July 2009 to 31st December 2010 (both dates inclusive), or” in section 43(2B)(a);

(zf)

by deleting subsection (11) of section 50;

(zg)

by deleting the words “and (9) to (12)” in section 50C(6) and substituting the words “, (9), (10) and (12)”;

(zh)

by deleting the words “Subject to subsection (3),” in section 100(2); and

(zi)

by deleting subsection (3) of section 100.

Related amendments to Stamp Duties Act

45. Section 15A of the Stamp Duties Act (Cap. 312) is amended —

(a)

by deleting the words “FRS 28, or SFRS for Small Entities, as amended from time to time” in subsection (18A) and substituting the words “FRS 28, SFRS(I) 1‑28, or SFRS for Small Entities”;

(b)

by deleting the definition of “FRS 28” in subsection (19) and substituting the following definitions:

“ “FRS 28”, “SFRS(I) 1-28” and “SFRS for Small Entities” mean the financial reporting standards known respectively as —

(a)	Financial Reporting Standard 28 (Investments in Associates and Joint Ventures);
(b)	Singapore Financial Reporting Standard (International) 1‑28 (Investments in Associates and Joint Ventures); and
(c)	Singapore Financial Reporting Standard for Small Entities,

that are made by the Accounting Standards Council under Part III of the Accounting Standards Act (Cap. 2B), as amended from time to time;”; and

(c)

by deleting the definition of “SFRS for Small Entities” in subsection (19).

Remission of tax for year of assessment 2019

46.—(1) There is to be remitted the tax payable for the year of assessment 2019 by an individual resident in Singapore an amount equal to the lower of the following:

(a)	50% of the tax payable by that individual for that year of assessment;
(b)	$200.

(2) The amount of such remission is to be determined by the Comptroller.

Saving and transitional provisions

47. For a period of 2 years after the date of commencement of any provision of this Act, the Minister may, by regulations, prescribe such additional provisions of a saving or transitional nature consequent on the enactment of that provision as the Minister may consider necessary or expedient.

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