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)
on or after 1st January 2004 ––
(i)
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 any 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;
(ii)
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 586/2008 wef 17/02/2006]
(b)
on or after 17th February 2006, managing the funds of an approved company for the purpose of any designated investments, or providing investment advisory services to an approved company in respect of any designated investments;
[S 586/2008 wef 17/02/2006]
[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.