3.—(1) 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 in its capacity as a trustee of a relevant foreign trust, or as a trustee of a philanthropic purpose trust in respect of a foreign account;
(b)
any trustee or custodian services for or on behalf of any unit trust which is also a trust fund that qualifies as a “foreign investor” as defined in the Income Tax (Concessionary Rate of Tax for Financial Sector Incentive Companies) Regulations 2005 and where the funds of the unit trust are invested in designated investments;
(c)
trustee or custodian services in respect of foreign bond or loan stock issues including services for monitoring loan covenants and administering loan repayments;
(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;
(e)
any custodian services for or on behalf of any foreign mutual fund corporation, where the funds of the foreign mutual fund corporation are invested in designated investments;
(f)
any trust management or administration services provided to any trustee of a relevant foreign trust, to any eligible holding company of a relevant foreign trust or to any trustee of a philanthropic purpose trust in respect of a foreign account; and
(g)
any trustee or custodian services in respect of the issue of units of —
(i)
a foreign collective investment scheme; or
(ii)
a foreign business trust,
where the proceeds of the issue of units are used outside Singapore.
[S 771/2017 wef 01/04/2016]
(2) Tax is payable at the rate of 10% on the income of an approved trustee company derived on or after 1 April 2016 from providing custodian services in respect of —
(a)
any qualifying debt securities;
(b)
any foreign debt securities;
(c)
any foreign equity securities;
(d)
any units in a foreign collective investment scheme; or