5% tax payable on qualifying income of financial sector incentive company
8. Tax shall be payable at the rate of 5% on the income derived on or after 1st January 2004 —
(a)
by a financial sector incentive (bond market) company from arranging, underwriting or distributing any qualifying debt securities, subject to the conditions specified in the Income Tax (Qualifying Debt Securities) Regulations (Rg 35);
(b)
by a financial sector incentive (credit facilities syndication) company from arranging, underwriting or granting loans under any syndicated offshore facility which is an offshore credit facility or an offshore guarantee facility, where the agreement for the facility is made on or after 1st January 2004, subject to the conditions specified in the Income Tax (Exemption of Income from Syndicated Offshore Facilities) Regulations 2003 (G.N. No. S 183/2003);
(c)
by a financial sector incentive (credit facilities syndication) company which is a bank licensed under the Banking Act (Cap. 19) or a merchant bank approved under section 28 of the Monetary Authority of Singapore Act (Cap. 186) from trading in secondary loans under any syndicated offshore facility which is an offshore credit facility or an offshore guarantee facility, where the agreement for the facility is made on or after 1st January 2004, subject to the conditions specified in the Income Tax (Exemption of Income from Syndicated Offshore Facilities) Regulations 2003;
(d)
by a financial sector incentive (derivatives market) company from trading in qualifying derivatives or providing services as an intermediary in connection with transactions relating to qualifying derivatives;
(e)
by a financial sector incentive (equity market) company from the following activities:
(i)
services (including services as a broker, nominee or custodian) in connection with transactions relating to stocks, shares, bonds or other securities listed on the Singapore Exchange that are issued by —
(A)
a company which is neither incorporated in Singapore nor resident in Singapore; or
(B)
a company which —
(BA)
is incorporated in Singapore;
(BB)
has at least 50% of its annual turnover derived from outside Singapore; and
(BC)
is approved for the purpose of these Regulations by the Minister or approving authority,
except where the payments for these services and other expenses in connection with the transactions are borne, directly or indirectly, by a person resident in Singapore or by a permanent establishment in Singapore of a person who is not resident in Singapore;
(ii)
the sale of any stocks, shares, bonds or other securities referred to in sub-paragraph (i);
(iii)
services on behalf of a company which is neither incorporated in Singapore nor resident in Singapore (excluding any permanent establishment it may have in Singapore) in respect of the arrangement, underwriting, management and placement of an initial public offering by the company of securities for the purpose of a listing on the Singapore Exchange, where the payments for these services and other expenses in connection with the issue of such securities are not borne, directly or indirectly, by a person resident in Singapore or a permanent establishment in Singapore; and
(iv)
services on behalf of a company which —
(A)
is incorporated in Singapore;
(B)
has at least 50% of its annual turnover derived from outside Singapore; and
(C)
is approved, for the purpose of these Regulations, by the Minister or approving authority,
in respect of the arrangement, underwriting, management and placement of an initial public offering by the company of securities for the purpose of a listing on the Singapore Exchange; and
(f)
by a financial sector incentive (project finance) company from any of the following activities:
(i)
arranging, underwriting or distributing any qualifying project debt securities;
(ii)
arranging or underwriting any qualifying project loan;
(iii)
providing project finance advisory services in connection with transactions relating to any prescribed asset or project.