6. The principal Regulations are amended by inserting, immediately after regulation 3, the following regulation:“Exemption from tax under section 13X(1)(b) of Act |
3A.—(1) Subject to the conditions in paragraph (2) and regulations 4, 5 and 6, there shall be exempt from tax, pursuant to section 13X(1)(b) of the Act, for any year of assessment —(a) | in the case of a company or trustee of a trust fund where the company or trust fund is the approved master fund or an approved feeder fund of an approved master-feeder fund structure, any specified income derived by the company or trustee arising from funds of the master fund or the feeder fund that are managed in Singapore by a fund manager in respect of designated investments; and | (b) | in the case of a partner of a limited partnership where the partnership is the approved master fund or an approved feeder fund of an approved master-feeder fund structure, the share to which the partner of the partnership is entitled in any specified income derived by the partnership arising from funds of the master fund or the feeder fund that are managed in Singapore by a fund manager in respect of designated investments. |
(2) The conditions referred to in paragraph (1) are — (a) | throughout the basis period for that year of assessment, the funds of the company, trust fund or limited partnership, as the case may be, are managed in Singapore by a fund manager; | (b) | at the time of the application for approval of the master-feeder fund structure —(i) | where no feeder fund carries on any income‑deriving activities at that time, the aggregate amount of — (A) | the funds of the master fund and all feeder funds of that structure managed in Singapore by the fund manager in Singapore; or | (B) | if the master-feeder fund structure is a private equity fund, a real estate fund or an infrastructure fund, the committed funds of the master fund and all feeder funds of that structure managed in Singapore by the fund manager in Singapore, |
is at least $50 million; or |
| (ii) | where any feeder fund carries on any income‑deriving activities at that time, the aggregate amount of —(A) | the funds of the master fund and all feeder funds of that structure managed in Singapore by the fund manager in Singapore; or | (B) | if the master-feeder fund structure is a private equity fund, a real estate fund or an infrastructure fund, the committed funds of the master fund and all feeder funds of that structure managed in Singapore by the fund manager in Singapore, |
is at least an amount which is computed in accordance with the following formula: |
| is the aggregate number of the master fund and feeder funds in that structure which are carrying on income-deriving activities at that time; and |
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| (c) | for that year of assessment, no part of the income of the approved master fund or any approved feeder fund of the approved master-feeder fund structure (other than any income derived before the approved master‑feeder fund structure was approved as such) —(i) | is exempt from tax under section 13C, 13CA, 13G, 13H, 13O, 13P, 13Q, 13R, 13W or 13Y of the Act; | (ii) | is subject to a concessionary rate of tax under section 43E, 43G or 43Q of the Act; or | (iii) | is entitled to any tax relief or concessionary rate of tax under Part III or IIIB of the Economic Expansion Incentives (Relief from Income Tax) Act (Cap. 86); |
| (d) | the investment strategy remains unchanged from the date the master-feeder fund structure is approved as an approved master-feeder fund structure; and | (e) | conditions specified in the letter of approval issued by the Monetary Authority of Singapore approving the master‑feeder fund structure under section 13X of the Act.”. |
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