§ 13E — Exemption of international shipping profits

13E.—(1) Subject to subsections (1A) and (2), there is exempt from tax the income of an approved international shipping enterprise derived —(a)

on or after 1 April 1991 from —(i)

the carriage of passengers, mail, livestock or goods from outside the limits of the port of Singapore by any foreign ship;

(ii)

the charter of any foreign ship to any person where such ship is used by the person for the carriage of passengers, mail, livestock or goods outside the limits of the port of Singapore; and

(iii)

the carriage of passengers, mail, livestock or goods by any foreign ship to Singapore solely for the purpose of transhipment;

(b)

for the year of assessment 2005 and subsequent years of assessment from —(i)

the operation outside the limits of the port of Singapore of any dredger, seismic ship or any ship used for offshore oil or gas activity; and

(ii)

the charter of any foreign dredger, foreign seismic ship, or any foreign ship used for offshore oil or gas activity to any person where such dredger, seismic ship or ship is used by the person for the person’s operation outside the limits of the port of Singapore;

(c)

for the year of assessment 2003 and subsequent years of assessment from —(i)

towing or salvage operations carried out from outside the limits of the port of Singapore by any foreign ship; and

(ii)

the charter of any foreign ship to any person where such ship is used by the person for towage and salvage operations carried out outside the limits of the port of Singapore;

(d)

for the year of assessment 2009 and subsequent years of assessment, from foreign exchange and risk management activities which are carried out in connection with and incidental to the operations described in paragraphs (a), (b) and (c);

(e)

at any time in the period between 22 February 2010 and 23 February 2015 (both dates inclusive) from the provision of ship management services to any qualifying special purpose vehicle in respect of ships owned or operated by the qualifying special purpose vehicle, unless the conditions of its approval otherwise provide;

(f)

for the year of assessment 2012 and subsequent years of assessment, from the carriage by any foreign ship of passengers, mail, livestock or goods which are shipped in Singapore, except where such carriage is only within the limits of the port of Singapore;

(g)

on or after 1 June 2011 from —(i)

the sale of a foreign ship used for a prescribed purpose;

(ii)

the assignment to another of all its rights as the buyer under a contract for the construction of a ship for a prescribed purpose that, at the time of assignment, is intended to be a foreign ship to be used for that or any other prescribed purpose; or

(iii)

the sale of all of the issued ordinary shares in a special purpose company of the approved international shipping enterprise where, at the time of the sale of the shares, the special purpose company —(A)

owns any foreign ship that is used for a prescribed purpose;

(B)

is the buyer under a contract for the construction of a foreign ship for a prescribed purpose that is intended to be used for that or any other prescribed purpose;

(C)

owns a Singapore ship or a provisionally registered ship within the meaning of section 13A(16); or[Act 33 of 2022 wef 04/11/2022]

(D)

is the buyer under a contract for the construction of a ship that, at the time of the sale, is intended to be registered or is provisionally registered under the Merchant Shipping Act 1995;

(h)

at any time during the period from 24 February 2015 to 18 February 2020 (both dates inclusive) from providing prescribed ship management services to any qualifying special purpose vehicle in respect of ships owned or operated by the qualifying special purpose vehicle, unless the conditions of its approval otherwise provide;

(i)

on or after 24 February 2015 from —(i)

any mobilisation or holding of any ship used or to be used for offshore oil or gas activity outside the limits of the port of Singapore; or

(ii)

the demobilisation of any ship after it has been so used,

where the mobilisation, holding or demobilisation is undertaken by the approved international shipping enterprise itself using a foreign ship;

(j)

on or after 24 February 2015 from —(i)

any mobilisation or holding of a foreign ship owned or operated by the approved international shipping enterprise and used or to be used for offshore oil or gas activity outside the limits of the port of Singapore; or

(ii)

the demobilisation of a foreign ship owned or operated by the approved international shipping enterprise after it has been so used;

(k)

on or after 24 February 2015 from the leasing of any container (other than finance leasing) carried out in connection with its operation of foreign ships and that is incidental to such operation;

(l)

during the period from 25 March 2016 to 18 February 2025 (both dates inclusive) from —(i)

the operation outside the limits of the port of Singapore of any foreign ship for offshore renewable energy activity; or[Act 25 of 2025 wef 19/02/2025]

(ii)

the charter of any foreign ship for offshore renewable energy activity to any person, where such ship is used by the person for the person’s operation outside the limits of the port of Singapore;[Act 25 of 2025 wef 19/02/2025]

(la)

on or after 19 February 2025 from —(i)

the operation outside the limits of the port of Singapore of any foreign ship for renewable energy activity; or

(ii)

the charter of any foreign ship for renewable energy activity to any person, where such ship is used by the person for the person’s operation outside the limits of the port of Singapore;[Act 25 of 2025 wef 19/02/2025]

(lb)

on or after 25 March 2016 from —(i)

the operation outside the limits of the port of Singapore of any foreign ship for offshore mineral activity; or

(ii)

the charter of any foreign ship for offshore mineral activity to any person, where such ship is used by the person for the person’s operation outside the limits of the port of Singapore;[Act 25 of 2025 wef 19/02/2025]

(m)

during the period from 25 March 2016 to 18 February 2025 (both dates inclusive) from —(i)

the sale of a foreign ship used for offshore renewable energy activity;[Act 25 of 2025 wef 19/02/2025]

(ii)

the assignment to another of all its rights as the buyer under a contract for the construction of a ship for offshore renewable energy activity that, at the time of assignment, is intended to be a foreign ship to be used for that activity or any prescribed purpose; or[Act 25 of 2025 wef 19/02/2025]

(iii)

the sale of all of the issued ordinary shares in a special purpose company of the approved international shipping enterprise where, at the time of the sale of the shares, the special purpose company —(A)

owns any foreign ship that is used for offshore renewable energy activity; or[Act 25 of 2025 wef 19/02/2025]

(B)

is the buyer under a contract for the construction of a foreign ship for that activity and that is intended to be used for that activity or any prescribed purpose;[Act 25 of 2025 wef 19/02/2025]

(ma)

on or after 19 February 2025 from —(i)

the sale of a foreign ship used for renewable energy activity;

(ii)

the assignment to another of all its rights as the buyer under a contract for the construction of a ship for renewable energy activity that, at the time of assignment, is intended to be a foreign ship to be used for that activity or any prescribed purpose; or

(iii)

the sale of all of the issued ordinary shares in a special purpose company of the approved international shipping enterprise where, at the time of the sale of the shares, the special purpose company —(A)

owns any foreign ship that is used for renewable energy activity; or

(B)

is the buyer under a contract for the construction of a foreign ship for that activity and that is intended to be used for that activity or any prescribed purpose;[Act 25 of 2025 wef 19/02/2025]

(mb)

on or after 25 March 2016 from —(i)

the sale of a foreign ship used for offshore mineral activity;

(ii)

the assignment to another of all its rights as the buyer under a contract for the construction of a ship for offshore mineral activity that, at the time of assignment, is intended to be a foreign ship to be used for that activity or any prescribed purpose; or

(iii)

the sale of all of the issued ordinary shares in a special purpose company of the approved international shipping enterprise where, at the time of the sale of the shares, the special purpose company —(A)

owns any foreign ship that is used for offshore mineral activity; or

(B)

is the buyer under a contract for the construction of a foreign ship for that activity and that is intended to be used for that activity or any prescribed purpose;[Act 25 of 2025 wef 19/02/2025]

(n)

during the period from 25 March 2016 to 18 February 2025 (both dates inclusive) from —(i)

any mobilisation or holding of any ship used or to be used for offshore renewable energy activity outside the limits of the port of Singapore; or[Act 25 of 2025 wef 19/02/2025]

(ii)

the demobilisation of any ship after it has been so used,

where the mobilisation, holding or demobilisation is undertaken by the approved international shipping enterprise itself using a foreign ship;

[Act 25 of 2025 wef 19/02/2025]

(na)

on or after 19 February 2025 from —(i)

any mobilisation or holding of any ship used or to be used for renewable energy activity outside the limits of the port of Singapore; or

(ii)

the demobilisation of any ship after it has been so used,

where the mobilisation, holding or demobilisation is undertaken by the approved international shipping enterprise itself using a foreign ship;

[Act 25 of 2025 wef 19/02/2025]

(nb)

on or after 25 March 2016 from —(i)

any mobilisation or holding of any ship used or to be used for offshore mineral activity outside the limits of the port of Singapore; or

(ii)

the demobilisation of any ship after it has been so used,

where the mobilisation, holding or demobilisation is undertaken by the approved international shipping enterprise itself using a foreign ship;

[Act 25 of 2025 wef 19/02/2025]

(o)

during the period from 25 March 2016 to 18 February 2025 (both dates inclusive) from —(i)

any mobilisation or holding of a foreign ship owned or operated by the approved international shipping enterprise and used or to be used for offshore renewable energy activity outside the limits of the port of Singapore; or[Act 25 of 2025 wef 19/02/2025]

(ii)

the demobilisation of a foreign ship owned or operated by the approved international shipping enterprise after it has been so used;[Act 25 of 2025 wef 19/02/2025]

(oa)

on or after 19 February 2025 from —(i)

any mobilisation or holding of a foreign ship owned or operated by the approved international shipping enterprise and used or to be used for renewable energy activity outside the limits of the port of Singapore; or

(ii)

the demobilisation of a foreign ship owned or operated by the approved international shipping enterprise after it has been so used;[Act 25 of 2025 wef 19/02/2025]

(ob)

on or after 25 March 2016 from —(i)

any mobilisation or holding of a foreign ship owned or operated by the approved international shipping enterprise and used or to be used for offshore mineral activity outside the limits of the port of Singapore; or

(ii)

the demobilisation of a foreign ship owned or operated by the approved international shipping enterprise after it has been so used;[Act 25 of 2025 wef 19/02/2025]

(p)

on or after 25 March 2016 from foreign exchange and risk management activities which are carried out in connection with and incidental to an activity described in paragraph (l), (lb), (n), (nb), (o) or (ob);[Act 25 of 2025 wef 19/02/2025]

(q)

on or after 29 December 2016 from foreign exchange and risk management activities that are carried out in connection with and incidental to an activity mentioned in subsection (1)(f), (h), (i) or (j);

(r)

on or after 12 December 2018 from —(i)

the finance leasing of any foreign ship to any person where the ship is used by the person for the carriage of passengers, mail, livestock or goods outside the limits of the port of Singapore;

(ii)

the finance leasing of any foreign dredger, foreign seismic ship, or any foreign ship used for offshore oil or gas activity to any person where the dredger, seismic ship or ship is used by the person for the person’s operation outside the limits of the port of Singapore;

(iii)

the finance leasing of any foreign ship to any person where the ship is used by the person for towage and salvage operations carried out outside the limits of the port of Singapore; and

(iv)

the finance leasing of any foreign ship to any person where the ship is used by the person for any of the following activities outside the limits of the port of Singapore:(A)

offshore renewable energy activity carried out before 19 February 2025;

(B)

renewable energy activity carried out on or after 19 February 2025; or

(C)

offshore mineral activity;[Act 25 of 2025 wef 19/02/2025]

(s)

on or after 12 December 2018 from foreign exchange and risk management activities which are carried out in connection with and incidental to an activity mentioned in paragraph (r);[Act 25 of 2025 wef 19/02/2025]

(t)

on or after 19 February 2020 from providing prescribed ship management services to —(i)

any qualifying special purpose vehicle of the approved international shipping enterprise or another approved international shipping enterprise; or

(ii)

any qualifying shareholder of the approved international shipping enterprise,

in respect of ships owned or operated by the qualifying special purpose vehicle or qualifying shareholder (as the case may be), unless the conditions of its approval otherwise provide;

[Act 25 of 2025 wef 19/02/2025]

[Act 25 of 2025 wef 08/12/2025]

(u)

on or after 19 February 2025 from foreign exchange and risk management activities which are carried out in connection with and incidental to an activity mentioned in paragraph (la), (na) or (oa); and[Act 25 of 2025 wef 19/02/2025]

[Act 25 of 2025 wef 08/12/2025]

(v)

on or after the date of commencement of section 7(2)(c) of the Finance (Income Taxes) Act 2025, from foreign exchange and risk management activities which are carried out in connection with and incidental to an activity mentioned in paragraph (t).[Act 25 of 2025 wef 08/12/2025]

[2/2016; 34/2016; 32/2019; 41/2020]

(1A) Unless the Minister or such person as the Minister may appoint permits in a particular case, subsection (1)(e) does not apply to the provision by an approved international shipping enterprise of ship management services to a qualifying special purpose vehicle if at least 50% of the total number of the issued ordinary shares of the enterprise are beneficially owned, whether directly or indirectly, by another approved international shipping enterprise.

(1AA) Subsection (1)(g) does not apply to —(a)

any income of an approved international shipping enterprise derived before 12 December 2018 as a lessor of a foreign ship used for a prescribed purpose, under a finance lease that is treated as a sale under section 10C; or

(b)

any income of an approved international shipping enterprise that is derived as part of a business of trading in foreign ships used for a prescribed purpose, or of constructing for sale foreign ships for a prescribed purpose.[2/2016; 41/2020]

(1AB) Unless the Minister or such person as the Minister may appoint permits in a particular case, subsection (1)(h) does not apply to the provision by an approved international shipping enterprise of prescribed ship management services to a qualifying special purpose vehicle, if at least 50% of the total number of the issued ordinary shares of the enterprise are beneficially owned, whether directly or indirectly, by another approved international shipping enterprise.[2/2016]

(1AC) Subsection (1)(m), (ma) and (mb) does not apply to —(a)

any income of an approved international shipping enterprise derived before 12 December 2018 as a lessor of a foreign ship used for offshore renewable energy activity or offshore mineral activity, under a finance lease that is treated as a sale under section 10C; or

(b)

any income of an approved international shipping enterprise that is derived as part of a business of trading in foreign ships used for offshore renewable energy activity, renewable energy activity or offshore mineral activity, or of constructing for sale foreign ships for any of those activities.[34/2016; 41/2020]

[Act 25 of 2025 wef 19/02/2025]

(1AD) Subsection (1)(r) does not apply to any income derived by an approved international shipping enterprise as part of a business of trading in foreign ships or constructing for sale foreign ships for any operation or activity mentioned in that provision.[41/2020]

(1B) An application may be made to the Minister or authorised body for a company —(a)

which is an international shipping enterprise; or

(b)

which is not but intends to become an international shipping enterprise,

to be approved as an approved international shipping enterprise, and the company is deemed upon approval to be an approved international shipping enterprise.

[Act 41 of 2020 wef 12/04/2024]

(2) The exemption for each approved international shipping enterprise —(a)

is for such period not exceeding 10 years after the date of its approval as the Minister or authorised body may specify, except that the Minister or authorised body may extend the period so specified for any further periods, not exceeding 10 years at a time, as the Minister or authorised body thinks fit; or[Act 41 of 2020 wef 12/04/2024]

(b)

if, at the time of its approval, the company does not, in the opinion of the Minister or authorised body, satisfy such qualifying conditions as the Minister or authorised body may determine for the purposes of paragraph (a), is for such period not exceeding 5 years from the date of its approval as the Minister or authorised body may specify.[Act 41 of 2020 wef 12/04/2024]

(2A) The approval of an approved international shipping enterprise for a period of exemption referred to in subsection (2)(b) may only be granted at any time between 1 June 2011 and 31 December 2031 (both dates inclusive).[2/2016; 41/2020]

[Act 25 of 2025 wef 19/02/2025]

(3) In determining the amount of the income of an approved international shipping enterprise which is exempted under this section, the allowances provided for in sections 16, 17, 18, 18B, 18C, 19, 19A, 20, 21, 22 and 23 —(a)

must be taken into account even if no claim for those allowances has been made; and

(b)

may only be deducted against the income referred to in subsection (1), and the balance of those allowances is not available as a deduction against any other income, except that any balance remaining unabsorbed at the end of the tax exempt period is available as a deduction against any other income for the year of assessment which relates to the basis period in which the tax exemption ceases and for any subsequent year of assessment in accordance with section 23.

(4) Where an approved international shipping enterprise incurs a loss during the tax exempt period in respect of any operation, activity or service referred to in paragraphs (a) to (f), (h) to (lb) and (n) to (v) of subsection (1), that loss —(a)

must be deducted in accordance with section 37; and

(b)

may only be deducted against the income referred to in any of those paragraphs, and the balance of such loss is not available as a deduction against any other income, except that any balance remaining unabsorbed at the end of the tax exempt period is available as a deduction against any other income for the year of assessment which relates to the basis period in which the tax exemption ceases and for any subsequent year of assessment in accordance with section 37.[2/2016; 34/2016; 32/2019]

[Act 25 of 2025 wef 19/02/2025]

[Act 25 of 2025 wef 08/12/2025]

(4A) Where an approved international shipping enterprise incurs a loss on any sale or assignment referred to in subsection (1)(g), (m), (ma) or (mb) in any basis period falling, in whole or in part, within the tax exempt period, that loss may only be deducted against the gains derived from another sale or assignment referred to in subsection (1)(g), (m), (ma) or (mb) in that same basis period, and the balance of the loss is not available as a deduction against any other income.[34/2016]

[Act 25 of 2025 wef 19/02/2025]

(5) Section 13A(2), (2A), (4), (5), (7), (8) and (9) applies to an approved international shipping enterprise, except that any reference to a shipping enterprise is a reference to an approved international shipping enterprise.

(6) In this section —“approved” means approved by the Minister or an authorised body, subject to such conditions as the Minister or authorised body may impose;[Act 41 of 2020 wef 12/04/2024]

“container” has the meaning given by section 43P(7);

“demobilisation”, “finance leasing”, “holding”, “mobilisation” and “prescribed ship management services” have the meanings given by section 13A(16);

“foreign ship” means a seagoing ship other than a Singapore ship, or (on or after the date on which the Income Tax (Amendment) Act 2022 is published in the Gazette) a provisionally registered ship, within the meaning of section 13A(16);[Act 33 of 2022 wef 04/11/2022]

“international shipping enterprise” means a company resident in Singapore —(a)

owning or operating ships; or

(b)

which has a qualifying special purpose vehicle which owns or operates ships;

“prescribed purpose”, in relation to a ship, means use for —(a)

the carriage of passengers, mail, livestock or goods;

(b)

dredging, seismic, or offshore oil or gas activity;

(c)

a towing or salvage operation; or

(d)

the mobilisation, holding or demobilisation of another ship;

“ship” has the meaning given by section 2(1) of the Merchant Shipping Act 1995;

“ship management services” has the meaning given by section 13A(16);

“special purpose company”, in relation to an approved international shipping enterprise, means a company that is wholly‑owned by the shipping enterprise and whose only business or intended business is —(a)

any operation mentioned in subsection (1)(a), (b), (c), (f), (i) and (j);

(b)

any operation of a Singapore ship, or (on or after the date on which the Income Tax (Amendment) Act 2022 is published in the Gazette) a provisionally registered ship, as defined in section 13A(16);[Act 33 of 2022 wef 04/11/2022]

(c)

any operation or activity mentioned in subsection (1)(l), (n) or (o) that takes place during the period from 25 March 2016 to 18 February 2025 (both dates inclusive);[Act 25 of 2025 wef 19/02/2025]

(ca)

any operation or activity mentioned in subsection (1)(la), (na) or (oa) that takes place on or after 19 February 2025;[Act 25 of 2025 wef 19/02/2025]

(cb)

any operation or activity mentioned in subsection (1)(lb), (nb) or (ob) that takes place on or after 25 March 2016; or[Act 25 of 2025 wef 19/02/2025]

(d)

any operation or activity mentioned in subsection (1)(r) that takes place on or after 12 December 2018.[2/2016; 34/2016; 41/2020]

(7) In this section, “qualifying special purpose vehicle”, in relation to a company referred to in paragraph (b) of the definition of “international shipping enterprise” in subsection (6) or an approved international shipping enterprise (called in this subsection the entity), means —(a)

an approved company other than one mentioned in paragraph (b) —(i)

which is resident in Singapore; and[Act 25 of 2025 wef 19/02/2025]

(ii)

at least 50% of the total number of the issued ordinary shares of which are beneficially owned, whether directly or indirectly, by —(A)

the entity; or

(B)

a company which beneficially owns (whether directly or indirectly) at least 50% of the total number of the issued ordinary shares of the entity;[Act 25 of 2025 wef 19/02/2025]

(b)

an approved company —(i)

which is incorporated outside Singapore; and

(ii)

at least 25% of the total number of the issued ordinary shares of which are beneficially owned, whether directly or indirectly, by the entity;

(c)

an approved partnership —(i)

which is registered or formed outside Singapore; and

(ii)

of which the entity is entitled, whether directly or indirectly, to at least 25% of its income;

(d)

an approved company —(i)

which is resident in Singapore and is not one mentioned in sub-paragraph (ii), and at least 50% of the total number of the issued ordinary shares of which are beneficially owned directly by another company which is a qualifying special purpose vehicle by virtue of paragraph (a)(ii)(B); or[Act 25 of 2025 wef 19/02/2025]

(ii)

which is incorporated outside Singapore, and at least 25% of the total number of the issued ordinary shares of which are beneficially owned directly by another company which is a qualifying special purpose vehicle by virtue of paragraph (a)(ii)(B);

(e)

an approved partnership which is registered or formed outside Singapore and one of the partners of which is a company which is a qualifying special purpose vehicle by virtue of paragraph (a)(ii)(B), and is entitled to at least 25% of its income; or

(f)

any other partnership or company that is approved under subsection (8) as a qualifying special purpose vehicle of the entity, so long as it satisfies the conditions imposed under that subsection.[2/2016]

(7A) In subsection (1)(t), “qualifying shareholder”, in relation to an approved international shipping enterprise, means an approved company —(a)

that is incorporated and resident in Singapore; and

(b)

that beneficially owns (whether directly or indirectly) at least 50% of the total number of issued ordinary shares of the approved international shipping enterprise.[41/2020]

(8) The Minister or an authorised body may, in a particular case, and subject to such conditions as the Minister or authorised body considers fit to impose, approve any partnership or company not specified in paragraphs (a) to (e) of subsection (7), as a qualifying special purpose vehicle of the entity mentioned in that subsection.[13F

[2/2016]

[Act 41 of 2020 wef 12/04/2024]

—(1) Subject to subsections (1A) and (2), there is exempt from tax the income of an approved international shipping enterprise derived —(a)

on or after 1 April 1991 from —(i)

the carriage of passengers, mail, livestock or goods from outside the limits of the port of Singapore by any foreign ship;

(ii)

the charter of any foreign ship to any person where such ship is used by the person for the carriage of passengers, mail, livestock or goods outside the limits of the port of Singapore; and

(iii)

the carriage of passengers, mail, livestock or goods by any foreign ship to Singapore solely for the purpose of transhipment;

(b)

for the year of assessment 2005 and subsequent years of assessment from —(i)

the operation outside the limits of the port of Singapore of any dredger, seismic ship or any ship used for offshore oil or gas activity; and

(ii)

the charter of any foreign dredger, foreign seismic ship, or any foreign ship used for offshore oil or gas activity to any person where such dredger, seismic ship or ship is used by the person for the person’s operation outside the limits of the port of Singapore;

(c)

for the year of assessment 2003 and subsequent years of assessment from —(i)

towing or salvage operations carried out from outside the limits of the port of Singapore by any foreign ship; and

(ii)

the charter of any foreign ship to any person where such ship is used by the person for towage and salvage operations carried out outside the limits of the port of Singapore;

(d)

for the year of assessment 2009 and subsequent years of assessment, from foreign exchange and risk management activities which are carried out in connection with and incidental to the operations described in paragraphs (a), (b) and (c);

(e)

at any time in the period between 22 February 2010 and 23 February 2015 (both dates inclusive) from the provision of ship management services to any qualifying special purpose vehicle in respect of ships owned or operated by the qualifying special purpose vehicle, unless the conditions of its approval otherwise provide;

(f)

for the year of assessment 2012 and subsequent years of assessment, from the carriage by any foreign ship of passengers, mail, livestock or goods which are shipped in Singapore, except where such carriage is only within the limits of the port of Singapore;

(g)

on or after 1 June 2011 from —(i)

the sale of a foreign ship used for a prescribed purpose;

(ii)

the assignment to another of all its rights as the buyer under a contract for the construction of a ship for a prescribed purpose that, at the time of assignment, is intended to be a foreign ship to be used for that or any other prescribed purpose; or

(iii)

the sale of all of the issued ordinary shares in a special purpose company of the approved international shipping enterprise where, at the time of the sale of the shares, the special purpose company —(A)

owns any foreign ship that is used for a prescribed purpose;

(B)

is the buyer under a contract for the construction of a foreign ship for a prescribed purpose that is intended to be used for that or any other prescribed purpose;

(C)

owns a Singapore ship or a provisionally registered ship within the meaning of section 13A(16); or[Act 33 of 2022 wef 04/11/2022]

(D)

is the buyer under a contract for the construction of a ship that, at the time of the sale, is intended to be registered or is provisionally registered under the Merchant Shipping Act 1995;

(h)

at any time during the period from 24 February 2015 to 18 February 2020 (both dates inclusive) from providing prescribed ship management services to any qualifying special purpose vehicle in respect of ships owned or operated by the qualifying special purpose vehicle, unless the conditions of its approval otherwise provide;

(i)

on or after 24 February 2015 from —(i)

any mobilisation or holding of any ship used or to be used for offshore oil or gas activity outside the limits of the port of Singapore; or

(ii)

the demobilisation of any ship after it has been so used,

where the mobilisation, holding or demobilisation is undertaken by the approved international shipping enterprise itself using a foreign ship;

(j)

on or after 24 February 2015 from —(i)

any mobilisation or holding of a foreign ship owned or operated by the approved international shipping enterprise and used or to be used for offshore oil or gas activity outside the limits of the port of Singapore; or

(ii)

the demobilisation of a foreign ship owned or operated by the approved international shipping enterprise after it has been so used;

(k)

on or after 24 February 2015 from the leasing of any container (other than finance leasing) carried out in connection with its operation of foreign ships and that is incidental to such operation;

(l)

during the period from 25 March 2016 to 18 February 2025 (both dates inclusive) from —(i)

the operation outside the limits of the port of Singapore of any foreign ship for offshore renewable energy activity; or[Act 25 of 2025 wef 19/02/2025]

(ii)

the charter of any foreign ship for offshore renewable energy activity to any person, where such ship is used by the person for the person’s operation outside the limits of the port of Singapore;[Act 25 of 2025 wef 19/02/2025]

(la)

on or after 19 February 2025 from —(i)

the operation outside the limits of the port of Singapore of any foreign ship for renewable energy activity; or

(ii)

the charter of any foreign ship for renewable energy activity to any person, where such ship is used by the person for the person’s operation outside the limits of the port of Singapore;[Act 25 of 2025 wef 19/02/2025]

(lb)

on or after 25 March 2016 from —(i)

the operation outside the limits of the port of Singapore of any foreign ship for offshore mineral activity; or

(ii)

the charter of any foreign ship for offshore mineral activity to any person, where such ship is used by the person for the person’s operation outside the limits of the port of Singapore;[Act 25 of 2025 wef 19/02/2025]

(m)

during the period from 25 March 2016 to 18 February 2025 (both dates inclusive) from —(i)

the sale of a foreign ship used for offshore renewable energy activity;[Act 25 of 2025 wef 19/02/2025]

(ii)

the assignment to another of all its rights as the buyer under a contract for the construction of a ship for offshore renewable energy activity that, at the time of assignment, is intended to be a foreign ship to be used for that activity or any prescribed purpose; or[Act 25 of 2025 wef 19/02/2025]

(iii)

the sale of all of the issued ordinary shares in a special purpose company of the approved international shipping enterprise where, at the time of the sale of the shares, the special purpose company —(A)

owns any foreign ship that is used for offshore renewable energy activity; or[Act 25 of 2025 wef 19/02/2025]

(B)

is the buyer under a contract for the construction of a foreign ship for that activity and that is intended to be used for that activity or any prescribed purpose;[Act 25 of 2025 wef 19/02/2025]

(ma)

on or after 19 February 2025 from —(i)

the sale of a foreign ship used for renewable energy activity;

(ii)

the assignment to another of all its rights as the buyer under a contract for the construction of a ship for renewable energy activity that, at the time of assignment, is intended to be a foreign ship to be used for that activity or any prescribed purpose; or

(iii)

the sale of all of the issued ordinary shares in a special purpose company of the approved international shipping enterprise where, at the time of the sale of the shares, the special purpose company —(A)

owns any foreign ship that is used for renewable energy activity; or

(B)

is the buyer under a contract for the construction of a foreign ship for that activity and that is intended to be used for that activity or any prescribed purpose;[Act 25 of 2025 wef 19/02/2025]

(mb)

on or after 25 March 2016 from —(i)

the sale of a foreign ship used for offshore mineral activity;

(ii)

the assignment to another of all its rights as the buyer under a contract for the construction of a ship for offshore mineral activity that, at the time of assignment, is intended to be a foreign ship to be used for that activity or any prescribed purpose; or

(iii)

the sale of all of the issued ordinary shares in a special purpose company of the approved international shipping enterprise where, at the time of the sale of the shares, the special purpose company —(A)

owns any foreign ship that is used for offshore mineral activity; or

(B)

is the buyer under a contract for the construction of a foreign ship for that activity and that is intended to be used for that activity or any prescribed purpose;[Act 25 of 2025 wef 19/02/2025]

(n)

during the period from 25 March 2016 to 18 February 2025 (both dates inclusive) from —(i)

any mobilisation or holding of any ship used or to be used for offshore renewable energy activity outside the limits of the port of Singapore; or[Act 25 of 2025 wef 19/02/2025]

(ii)

the demobilisation of any ship after it has been so used,

where the mobilisation, holding or demobilisation is undertaken by the approved international shipping enterprise itself using a foreign ship;

[Act 25 of 2025 wef 19/02/2025]

(na)

on or after 19 February 2025 from —(i)

any mobilisation or holding of any ship used or to be used for renewable energy activity outside the limits of the port of Singapore; or

(ii)

the demobilisation of any ship after it has been so used,

where the mobilisation, holding or demobilisation is undertaken by the approved international shipping enterprise itself using a foreign ship;

[Act 25 of 2025 wef 19/02/2025]

(nb)

on or after 25 March 2016 from —(i)

any mobilisation or holding of any ship used or to be used for offshore mineral activity outside the limits of the port of Singapore; or

(ii)

the demobilisation of any ship after it has been so used,

where the mobilisation, holding or demobilisation is undertaken by the approved international shipping enterprise itself using a foreign ship;

[Act 25 of 2025 wef 19/02/2025]

(o)

during the period from 25 March 2016 to 18 February 2025 (both dates inclusive) from —(i)

any mobilisation or holding of a foreign ship owned or operated by the approved international shipping enterprise and used or to be used for offshore renewable energy activity outside the limits of the port of Singapore; or[Act 25 of 2025 wef 19/02/2025]

(ii)

the demobilisation of a foreign ship owned or operated by the approved international shipping enterprise after it has been so used;[Act 25 of 2025 wef 19/02/2025]

(oa)

on or after 19 February 2025 from —(i)

any mobilisation or holding of a foreign ship owned or operated by the approved international shipping enterprise and used or to be used for renewable energy activity outside the limits of the port of Singapore; or

(ii)

the demobilisation of a foreign ship owned or operated by the approved international shipping enterprise after it has been so used;[Act 25 of 2025 wef 19/02/2025]

(ob)

on or after 25 March 2016 from —(i)

any mobilisation or holding of a foreign ship owned or operated by the approved international shipping enterprise and used or to be used for offshore mineral activity outside the limits of the port of Singapore; or

(ii)

the demobilisation of a foreign ship owned or operated by the approved international shipping enterprise after it has been so used;[Act 25 of 2025 wef 19/02/2025]

(p)

on or after 25 March 2016 from foreign exchange and risk management activities which are carried out in connection with and incidental to an activity described in paragraph (l), (lb), (n), (nb), (o) or (ob);[Act 25 of 2025 wef 19/02/2025]

(q)

on or after 29 December 2016 from foreign exchange and risk management activities that are carried out in connection with and incidental to an activity mentioned in subsection (1)(f), (h), (i) or (j);

(r)

on or after 12 December 2018 from —(i)

the finance leasing of any foreign ship to any person where the ship is used by the person for the carriage of passengers, mail, livestock or goods outside the limits of the port of Singapore;

(ii)

the finance leasing of any foreign dredger, foreign seismic ship, or any foreign ship used for offshore oil or gas activity to any person where the dredger, seismic ship or ship is used by the person for the person’s operation outside the limits of the port of Singapore;

(iii)

the finance leasing of any foreign ship to any person where the ship is used by the person for towage and salvage operations carried out outside the limits of the port of Singapore; and

(iv)

the finance leasing of any foreign ship to any person where the ship is used by the person for any of the following activities outside the limits of the port of Singapore:(A)

offshore renewable energy activity carried out before 19 February 2025;

(B)

renewable energy activity carried out on or after 19 February 2025; or

(C)

offshore mineral activity;[Act 25 of 2025 wef 19/02/2025]

(s)

on or after 12 December 2018 from foreign exchange and risk management activities which are carried out in connection with and incidental to an activity mentioned in paragraph (r);[Act 25 of 2025 wef 19/02/2025]

(t)

on or after 19 February 2020 from providing prescribed ship management services to —(i)

any qualifying special purpose vehicle of the approved international shipping enterprise or another approved international shipping enterprise; or

(ii)

any qualifying shareholder of the approved international shipping enterprise,

in respect of ships owned or operated by the qualifying special purpose vehicle or qualifying shareholder (as the case may be), unless the conditions of its approval otherwise provide;

[Act 25 of 2025 wef 19/02/2025]

[Act 25 of 2025 wef 08/12/2025]

(u)

on or after 19 February 2025 from foreign exchange and risk management activities which are carried out in connection with and incidental to an activity mentioned in paragraph (la), (na) or (oa); and[Act 25 of 2025 wef 19/02/2025]

[Act 25 of 2025 wef 08/12/2025]

(v)

on or after the date of commencement of section 7(2)(c) of the Finance (Income Taxes) Act 2025, from foreign exchange and risk management activities which are carried out in connection with and incidental to an activity mentioned in paragraph (t).[Act 25 of 2025 wef 08/12/2025]

[2/2016; 34/2016; 32/2019; 41/2020]

(1A) Unless the Minister or such person as the Minister may appoint permits in a particular case, subsection (1)(e) does not apply to the provision by an approved international shipping enterprise of ship management services to a qualifying special purpose vehicle if at least 50% of the total number of the issued ordinary shares of the enterprise are beneficially owned, whether directly or indirectly, by another approved international shipping enterprise.

(1AA) Subsection (1)(g) does not apply to —(a)

any income of an approved international shipping enterprise derived before 12 December 2018 as a lessor of a foreign ship used for a prescribed purpose, under a finance lease that is treated as a sale under section 10C; or

(b)

any income of an approved international shipping enterprise that is derived as part of a business of trading in foreign ships used for a prescribed purpose, or of constructing for sale foreign ships for a prescribed purpose.[2/2016; 41/2020]

(1AB) Unless the Minister or such person as the Minister may appoint permits in a particular case, subsection (1)(h) does not apply to the provision by an approved international shipping enterprise of prescribed ship management services to a qualifying special purpose vehicle, if at least 50% of the total number of the issued ordinary shares of the enterprise are beneficially owned, whether directly or indirectly, by another approved international shipping enterprise.[2/2016]

(1AC) Subsection (1)(m), (ma) and (mb) does not apply to —(a)

any income of an approved international shipping enterprise derived before 12 December 2018 as a lessor of a foreign ship used for offshore renewable energy activity or offshore mineral activity, under a finance lease that is treated as a sale under section 10C; or

(b)

any income of an approved international shipping enterprise that is derived as part of a business of trading in foreign ships used for offshore renewable energy activity, renewable energy activity or offshore mineral activity, or of constructing for sale foreign ships for any of those activities.[34/2016; 41/2020]

[Act 25 of 2025 wef 19/02/2025]

(1AD) Subsection (1)(r) does not apply to any income derived by an approved international shipping enterprise as part of a business of trading in foreign ships or constructing for sale foreign ships for any operation or activity mentioned in that provision.[41/2020]

(1B) An application may be made to the Minister or authorised body for a company —(a)

which is an international shipping enterprise; or

(b)

which is not but intends to become an international shipping enterprise,

to be approved as an approved international shipping enterprise, and the company is deemed upon approval to be an approved international shipping enterprise.

[Act 41 of 2020 wef 12/04/2024]

(2) The exemption for each approved international shipping enterprise —(a)

is for such period not exceeding 10 years after the date of its approval as the Minister or authorised body may specify, except that the Minister or authorised body may extend the period so specified for any further periods, not exceeding 10 years at a time, as the Minister or authorised body thinks fit; or[Act 41 of 2020 wef 12/04/2024]

(b)

if, at the time of its approval, the company does not, in the opinion of the Minister or authorised body, satisfy such qualifying conditions as the Minister or authorised body may determine for the purposes of paragraph (a), is for such period not exceeding 5 years from the date of its approval as the Minister or authorised body may specify.[Act 41 of 2020 wef 12/04/2024]

(2A) The approval of an approved international shipping enterprise for a period of exemption referred to in subsection (2)(b) may only be granted at any time between 1 June 2011 and 31 December 2031 (both dates inclusive).[2/2016; 41/2020]

[Act 25 of 2025 wef 19/02/2025]

(3) In determining the amount of the income of an approved international shipping enterprise which is exempted under this section, the allowances provided for in sections 16, 17, 18, 18B, 18C, 19, 19A, 20, 21, 22 and 23 —(a)

must be taken into account even if no claim for those allowances has been made; and

(b)

may only be deducted against the income referred to in subsection (1), and the balance of those allowances is not available as a deduction against any other income, except that any balance remaining unabsorbed at the end of the tax exempt period is available as a deduction against any other income for the year of assessment which relates to the basis period in which the tax exemption ceases and for any subsequent year of assessment in accordance with section 23.

(4) Where an approved international shipping enterprise incurs a loss during the tax exempt period in respect of any operation, activity or service referred to in paragraphs (a) to (f), (h) to (lb) and (n) to (v) of subsection (1), that loss —(a)

must be deducted in accordance with section 37; and

(b)

may only be deducted against the income referred to in any of those paragraphs, and the balance of such loss is not available as a deduction against any other income, except that any balance remaining unabsorbed at the end of the tax exempt period is available as a deduction against any other income for the year of assessment which relates to the basis period in which the tax exemption ceases and for any subsequent year of assessment in accordance with section 37.[2/2016; 34/2016; 32/2019]

[Act 25 of 2025 wef 19/02/2025]

[Act 25 of 2025 wef 08/12/2025]

(4A) Where an approved international shipping enterprise incurs a loss on any sale or assignment referred to in subsection (1)(g), (m), (ma) or (mb) in any basis period falling, in whole or in part, within the tax exempt period, that loss may only be deducted against the gains derived from another sale or assignment referred to in subsection (1)(g), (m), (ma) or (mb) in that same basis period, and the balance of the loss is not available as a deduction against any other income.[34/2016]

[Act 25 of 2025 wef 19/02/2025]

(5) Section 13A(2), (2A), (4), (5), (7), (8) and (9) applies to an approved international shipping enterprise, except that any reference to a shipping enterprise is a reference to an approved international shipping enterprise.

(6) In this section —“approved” means approved by the Minister or an authorised body, subject to such conditions as the Minister or authorised body may impose;[Act 41 of 2020 wef 12/04/2024]

“container” has the meaning given by section 43P(7);

“demobilisation”, “finance leasing”, “holding”, “mobilisation” and “prescribed ship management services” have the meanings given by section 13A(16);

“foreign ship” means a seagoing ship other than a Singapore ship, or (on or after the date on which the Income Tax (Amendment) Act 2022 is published in the Gazette) a provisionally registered ship, within the meaning of section 13A(16);[Act 33 of 2022 wef 04/11/2022]

“international shipping enterprise” means a company resident in Singapore —(a)

owning or operating ships; or

(b)

which has a qualifying special purpose vehicle which owns or operates ships;

“prescribed purpose”, in relation to a ship, means use for —(a)

the carriage of passengers, mail, livestock or goods;

(b)

dredging, seismic, or offshore oil or gas activity;

(c)

a towing or salvage operation; or

(d)

the mobilisation, holding or demobilisation of another ship;

“ship” has the meaning given by section 2(1) of the Merchant Shipping Act 1995;

“ship management services” has the meaning given by section 13A(16);

“special purpose company”, in relation to an approved international shipping enterprise, means a company that is wholly‑owned by the shipping enterprise and whose only business or intended business is —(a)

any operation mentioned in subsection (1)(a), (b), (c), (f), (i) and (j);

(b)

any operation of a Singapore ship, or (on or after the date on which the Income Tax (Amendment) Act 2022 is published in the Gazette) a provisionally registered ship, as defined in section 13A(16);[Act 33 of 2022 wef 04/11/2022]

(c)

any operation or activity mentioned in subsection (1)(l), (n) or (o) that takes place during the period from 25 March 2016 to 18 February 2025 (both dates inclusive);[Act 25 of 2025 wef 19/02/2025]

(ca)

any operation or activity mentioned in subsection (1)(la), (na) or (oa) that takes place on or after 19 February 2025;[Act 25 of 2025 wef 19/02/2025]

(cb)

any operation or activity mentioned in subsection (1)(lb), (nb) or (ob) that takes place on or after 25 March 2016; or[Act 25 of 2025 wef 19/02/2025]

(d)

any operation or activity mentioned in subsection (1)(r) that takes place on or after 12 December 2018.[2/2016; 34/2016; 41/2020]

(7) In this section, “qualifying special purpose vehicle”, in relation to a company referred to in paragraph (b) of the definition of “international shipping enterprise” in subsection (6) or an approved international shipping enterprise (called in this subsection the entity), means —(a)

an approved company other than one mentioned in paragraph (b) —(i)

which is resident in Singapore; and[Act 25 of 2025 wef 19/02/2025]

(ii)

at least 50% of the total number of the issued ordinary shares of which are beneficially owned, whether directly or indirectly, by —(A)

the entity; or

(B)

a company which beneficially owns (whether directly or indirectly) at least 50% of the total number of the issued ordinary shares of the entity;[Act 25 of 2025 wef 19/02/2025]

(b)

an approved company —(i)

which is incorporated outside Singapore; and

(ii)

at least 25% of the total number of the issued ordinary shares of which are beneficially owned, whether directly or indirectly, by the entity;

(c)

an approved partnership —(i)

which is registered or formed outside Singapore; and

(ii)

of which the entity is entitled, whether directly or indirectly, to at least 25% of its income;

(d)

an approved company —(i)

which is resident in Singapore and is not one mentioned in sub-paragraph (ii), and at least 50% of the total number of the issued ordinary shares of which are beneficially owned directly by another company which is a qualifying special purpose vehicle by virtue of paragraph (a)(ii)(B); or[Act 25 of 2025 wef 19/02/2025]

(ii)

which is incorporated outside Singapore, and at least 25% of the total number of the issued ordinary shares of which are beneficially owned directly by another company which is a qualifying special purpose vehicle by virtue of paragraph (a)(ii)(B);

(e)

an approved partnership which is registered or formed outside Singapore and one of the partners of which is a company which is a qualifying special purpose vehicle by virtue of paragraph (a)(ii)(B), and is entitled to at least 25% of its income; or

(f)

any other partnership or company that is approved under subsection (8) as a qualifying special purpose vehicle of the entity, so long as it satisfies the conditions imposed under that subsection.[2/2016]

(7A) In subsection (1)(t), “qualifying shareholder”, in relation to an approved international shipping enterprise, means an approved company —(a)

that is incorporated and resident in Singapore; and

(b)

that beneficially owns (whether directly or indirectly) at least 50% of the total number of issued ordinary shares of the approved international shipping enterprise.[41/2020]

(8) The Minister or an authorised body may, in a particular case, and subject to such conditions as the Minister or authorised body considers fit to impose, approve any partnership or company not specified in paragraphs (a) to (e) of subsection (7), as a qualifying special purpose vehicle of the entity mentioned in that subsection.[13F

[2/2016]

[Act 41 of 2020 wef 12/04/2024]