3. Tax shall be payable at the rate of 10% on the income derived by an approved trustee company from the provision of —
(a)
any trustee or custodian services arising from a trust by deed where both the settlor and beneficiaries of the trust are —
(i)
in the case of individuals, neither citizens of Singapore nor resident in Singapore; and
(ii)
in the case of companies, neither incorporated nor resident in Singapore and where such a company has not more than 50 shareholders, the whole of its issued capital is beneficially owned, directly or indirectly, by persons who are neither citizens of Singapore nor resident in Singapore; and where such a company has more than 50 shareholders, not less than 95% of its issued capital is beneficially owned, directly or indirectly, by persons who are neither citizens of Singapore nor resident in Singapore;
(b)
any trustee or custodian services for or on behalf of any unit trust which falls within paragraph (c) in the definition of “foreign investor” in the Income Tax (Income from Funds Managed for Foreign Investors) Regulations and where the funds of the unit trust are invested in designated investments within the meaning of those Regulations;
[Rg. 8.]
(c)
trustee or custodian services in respect of foreign bond or loan stock issues including services for monitoring loan covenants and administering loan repayments; and
(d)
custodian services in respect of stocks and shares, denominated in currencies other than Singapore dollars, of companies which are neither incorporated nor resident in Singapore.