10% tax payable on qualifying income of financial sector incentive (headquarter services) company
6.—(1)  Tax is payable at the rate of 10% on the income of a financial sector incentive (headquarter services) company derived from the provision of any of the following services, to any approved office of the financial sector incentive (headquarter services) company or any approved person:
(a)general management, risk management and administration;
(b)strategic business planning and strategic business development;
(c)operational processing services;
(d)information technology support and technical services;
(e)training and personnel management;
(f)corporate finance advisory services;
(g)economic, financial, investment or market research and analysis;
(h)credit control and administration;
(i)arranging credit facilities for the approved office where the funds for providing the facilities are obtained from —
(i)financial institutions in Singapore; or
(ii)the accumulated profits of other approved offices;
(j)providing guarantees, performance bonds, standby letters of credit and services relating to remittances where —
(i)in the case of a guarantee, performance bond or standby letter of credit, the party in whose favour the facility is issued; and
(ii)in the case of services relating to remittances, the person to whom the remittances are made,
is a financial institution;
(k)arranging interest rate or currency swaps with a financial institution;
(l)managing the funds of the approved office.
(2)  Tax is payable at the rate of 10% on the income of a financial sector incentive (headquarter services) company derived from the provision of any prescribed processing services in Singapore to any financial institution or another financial sector incentive (headquarter services) company.
(3)  In this regulation —
“approved office”, in relation to a financial sector incentive (headquarter services) company, means an office or associated company of the financial sector incentive (headquarter services) company, whether in or outside Singapore, that is approved by the Minister or approving authority;
“approved person”, in relation to a financial sector incentive (headquarter services) company, means a person, whether in or outside Singapore, that is not an approved office of the financial sector incentive (headquarter services) company, and that is approved by the Minister or approving authority for the purposes of this regulation;
“associated company”, in relation to a financial sector incentive (headquarter services) company, means a company —
(a)the operations of which are or can be controlled, directly or indirectly, by that financial sector incentive (headquarter services) company;
(b)that controls or can control, directly or indirectly, the operations of that financial sector incentive (headquarter services) company; or
(c)the operations of which are or can be controlled, directly or indirectly, by a person or persons that control or can control, directly or indirectly, the operations of that financial sector incentive (headquarter services) company;
“financial institution” means —
(a)any institution in Singapore that is licensed or approved by the Monetary Authority of Singapore, or exempt from such licensing or approval, under any written law administered by the Monetary Authority of Singapore; or
(b)any institution outside Singapore that is licensed or approved, or exempt from such licensing or approval, by its financial supervisory authority for the carrying on of financial activities;
“prescribed processing services” means any of the services specified in the Second Schedule.
(4)  For the purpose of the definition of “associated company” in paragraph (3) —
(a)a company is treated as controlling, directly or indirectly, the operations of a financial sector incentive (headquarter services) company if the company beneficially owns, directly or indirectly, at least 25% of the total number of the issued shares of the financial sector incentive (headquarter services) company; and
(b)a financial sector incentive (headquarter services) company is treated as controlling, directly or indirectly, the operations of another company if the financial sector incentive (headquarter services) company beneficially owns, directly or indirectly, at least 25% of the total number of the issued shares of that company.