10% tax payable on qualifying income of financial sector incentive (fund management) company
6.—(1) Subject to regulation 7, tax shall be payable at the rate of 10% on the income of a financial sector incentive (fund management) company derived from the following activities:
(a)
managing the funds of a foreign investor for the purpose of any designated investments, or providing investment advisory services to a foreign investor in respect of designated investments, where the payments for the services are not borne, directly or indirectly, by a person resident in Singapore or by a permanent establishment in Singapore;
(b)
arranging, on behalf of a foreign investor, any loan of designated securities under a securities lending arrangement in writing to a financial sector incentive (standard tier) company or another financial sector incentive (fund management) company, where the payments for the services are not borne, directly or indirectly, by a person resident in Singapore or by a permanent establishment in Singapore.
[S 260/2006 wef 18/02/2005]
(2) Tax shall be payable at the rate of 10% on the income of a financial sector incentive (fund management) company which is an approved start-up fund manager, derived during a period of 12 months from the date of the incorporation, by that company, of a fund in the form of a company not resident in Singapore, from —
(a)
managing the funds of the second-mentioned company for the purpose of any designated investment;
(b)
providing investment advisory services to the second-mentioned company in respect of designated investments; or
(c)
arranging, on behalf of the second-mentioned company, any loan of designated securities under a securities lending arrangement in writing to a financial sector incentive (standard tier) company or another financial sector incentive (fund management) company,
provided that —
(i)
the second-mentioned company was incorporated at any time between 18th February 2005 and 17th February 2010 (both dates inclusive);
(ii)
the date of incorporation of the second-mentioned company is stated in its charter, statute or memorandum and articles or other instrument constituting it or defining its constitution;
(iii)
at the date of incorporation of the second-mentioned company, the first-mentioned company was already an approved start-up company;
(iv)
the second-mentioned company has been managed by the first-mentioned company since the date of incorporation of the second-mentioned company; and
(v)
the second-mentioned company was not incorporated with the avoidance or reduction of tax chargeable under the Act as its main purpose or one of its main purposes.
[S 260/2006 wef 18/02/2005]
(3) Tax shall be payable at the rate of 10% on the income of a financial sector incentive (fund management) company which is an approved start-up fund manager, derived during a period of 12 months from the date of the constitution, by that company, of a trust fund, from —
(a)
managing the funds of the trust fund for the purpose of any designated investment;
(b)
providing investment advisory services to the trust fund in respect of designated investments; or
(c)
arranging, on behalf of the trust fund, any loan of designated securities under a securities lending arrangement in writing to a financial sector incentive (standard tier) company or another financial sector incentive (fund management) company,
provided that —
(i)
the trust fund was constituted at any time between 18th February 2005 and 17th February 2010 (both dates inclusive);
(ii)
the date of constitution of the trust fund is stated in the relevant trust instrument;
(iii)
at the date of constitution of the trust fund, the company was already an approved start-up company;
(iv)
the trust fund has been managed by that company since the constitution of that trust fund; and
(v)
the trust fund was not constituted with the avoidance or reduction of tax chargeable under the Act as its main purpose or one of its main purposes.