§ 13U — Exemption of income arising from funds managed by fund manager in Singapore

13U.—(1) Subject to such conditions as may be prescribed by regulations, or specified in the letter of approval of the person, master fund, feeder fund, SPV, master‑feeder fund structure, master‑feeder fund‑SPV structure or master fund‑SPV structure, or specified from time to time by the Minister or an authorised body and either notified to the holder of the letter of approval or published in a manner that the Minister or authorised body reasonably believes will bring the conditions to the notice of the holder of the letter of approval, there is exempt from tax such income as the Minister may by regulations prescribe of —(a)

an approved person arising from funds managed in Singapore by a fund manager;

(b)

in relation to an approved master‑feeder fund structure —(i)

a person (not being an individual, a body of persons or a Hindu joint family) that is an approved master fund or an approved feeder fund of the structure;

(ii)

a partner of a partnership (including a limited partnership and a limited liability partnership), where the partnership is the approved master fund or an approved feeder fund of the structure;

(iii)

a trustee of a trust fund where the trust fund is the approved master fund or an approved feeder fund of the structure; and

(iv)

a taxable entity in relation to the approved master fund or an approved feeder fund of the structure, where the master fund or feeder fund is not a legal entity,

arising from funds of the master fund or any feeder fund of that structure, that are managed in Singapore by a fund manager;

(c)

in relation to an approved master‑feeder fund‑SPV structure —(i)

a company, a trustee of a trust fund or a partner of a limited partnership, where the company, trust fund or limited partnership is the approved master fund or an approved feeder fund of the structure;

(ia)

a person (not being a company, an individual or a Hindu joint family) that is an approved feeder fund of the structure;

(ib)

a partner of a partnership (excluding a limited partnership but including a limited liability partnership), where the partnership is an approved feeder fund of the structure;

(ic)

a taxable entity in relation to an approved feeder fund of the structure, where the feeder fund is not a legal entity;

(ii)

an approved 1st tier SPV of the structure;

(iii)

an approved 2nd tier SPV of the structure;

(iv)

an approved eligible SPV of the structure, where the eligible SPV is not one mentioned in sub‑paragraphs (v), (vi) and (vii);

(v)

a partner of an approved eligible SPV of the structure, where the eligible SPV is a partnership (including a limited partnership and a limited liability partnership);

(vi)

the trustee of an approved eligible SPV of the structure, where the eligible SPV is a trust fund; and

(vii)

the taxable entity of an approved eligible SPV of the structure, where the eligible SPV is not a legal entity,

arising from funds of —

(viii)

the master fund;

(ix)

any feeder fund; or

(x)

any approved eligible SPV,

of that structure, that are managed in Singapore by a fund manager; or

[Act 33 of 2022 wef 19/02/2019]

(d)

in relation to an approved master fund‑SPV structure —(i)

a company, a trustee of a trust fund or a partner of a limited partnership, where the company, trust fund or limited partnership is the approved master fund of the structure;

(ii)

an approved 1st tier SPV of the structure;

(iii)

an approved 2nd tier SPV of the structure;

(iv)

an approved eligible SPV of the structure, where the eligible SPV is not one mentioned in sub‑paragraphs (v), (vi) and (vii);

(v)

a partner of an approved eligible SPV of the structure, where the eligible SPV is a partnership (including a limited partnership and a limited liability partnership);

(vi)

the trustee of an approved eligible SPV of the structure, where the eligible SPV is a trust fund; and

(vii)

the taxable entity of an approved eligible SPV of the structure, where the eligible SPV is not a legal entity,

arising from funds of the master fund or of any approved eligible SPV of that structure, that are managed in Singapore by a fund manager.

[2/2016; 45/2018; 32/2019]

[Act 33 of 2022 wef 19/02/2019]

[Act 35 of 2024 wef 17/02/2024]

(2) Approval under subsection (1)(a) may be granted during the period from 1 April 2009 to 31 December 2029 (both dates inclusive).[37/2014; 32/2019]

[Act 35 of 2024 wef 27/11/2024]

(2A) Approval under subsection (1)(b) may be granted during the period from 7 July 2010 to 31 December 2029 (both dates inclusive).[37/2014; 32/2019]

[Act 35 of 2024 wef 27/11/2024]

(2B) Approval under subsection (1)(c)(i) and (d)(i) may be granted during the period from 1 April 2015 to 31 December 2029 (both dates inclusive).[32/2019]

[Act 35 of 2024 wef 27/11/2024]

(2C) Approval under subsection (1)(c)(ia), (ib) and (ic) may be granted during the period from 20 February 2018 to 31 December 2029 (both dates inclusive).[32/2019]

[Act 35 of 2024 wef 27/11/2024]

(2D) Approval under subsection (1)(c)(ii) and (iii) and (d)(ii) and (iii) may be granted during the period from 1 April 2015 to 18 February 2019 (both dates inclusive).[32/2019]

(2E) Approval under subsection (1)(c)(iv), (v), (vi) and (vii) and (d)(iv), (v), (vi) and (vii) may be granted during the period from 19 February 2019 to 31 December 2029 (both dates inclusive).[32/2019]

[Act 35 of 2024 wef 27/11/2024]

(2F) An approval under subsection (1) is subject to such conditions as the Minister or an authorised body may impose.[Act 35 of 2024 wef 17/02/2024]

(2G) The Minister or an authorised body may at any time add, vary or delete a condition of an approval under subsection (2F), including (to avoid doubt) an approval given before the date of commencement of section 11(e) of the Income Tax (Amendment) Act 2024.[Act 35 of 2024 wef 27/11/2024]

(2H) Any addition, variation or deletion of a condition under subsection (2G) must be given to the holder of the letter of approval or published in a manner that the Minister or authorised body reasonably believes will bring the addition, variation or deletion to the attention of the holder of the approval.[Act 35 of 2024 wef 27/11/2024]

(3) Where the income of any approved person or person (including a company), trustee, partner, taxable entity, 1st tier SPV, 2nd tier SPV or eligible SPV referred to in subsection (1)(b), (c) or (d) is not exempt from tax under this section, sections 13C, 13D, 13O and 13OA do not apply to that income despite anything in those provisions.[2/2016; 45/2018; 32/2019]

[Act 35 of 2024 wef 01/01/2025]

(4) Regulations made under subsection (1) may —(a)

provide for the determination of the amount of income of any approved person or person (including a company), trustee, partner, taxable entity, 1st tier SPV, 2nd tier SPV or eligible SPV referred to in subsection (1)(b), (c) or (d) to be exempt from tax;

(b)

provide for the deduction of expenses, allowances and losses of any approved person or person (including a company), trustee, partner, taxable entity, 1st tier SPV, 2nd tier SPV or eligible SPV referred to in subsection (1)(b), (c) or (d) otherwise than in accordance with this Act;

(c)

where the approved person is a partner of an approved partnership (including a limited partnership and a limited liability partnership), provide for the recovery of tax from the partner in a case where the exemption ought not to have been allowed to the partner due to non‑compliance with any condition imposed on the partnership, including the deeming of a specified amount as income of the partner for the year of assessment in which the Comptroller discovers the non‑compliance of the condition;

(ca)

provide for the recovery of tax from a person (including a company), trustee, taxable entity, 1st tier SPV, 2nd tier SPV or eligible SPV referred to in subsection (1)(b), (c) or (d) in a case where the exemption ought not to have been allowed to the person due to non‑compliance with any condition imposed on the approved master‑feeder fund structure, approved master‑feeder fund‑SPV structure or approved master fund‑SPV structure, as the case may be;

(cb)

provide for the recovery of tax from a partner of a partnership (including a limited partnership and a limited liability partnership) referred to in subsection (1)(b), (c) or (d) in a case where the exemption ought not to have been allowed to that partner due to non‑compliance with any condition imposed on the approved master‑feeder fund structure, approved master‑feeder fund‑SPV structure or approved master fund‑SPV structure (as the case may be), including the deeming of a specified amount as income of the partner for the year of assessment in which the Comptroller discovers the non‑compliance with the condition; [Act 35 of 2024 wef 27/11/2024]

(cc)

provide for the revocation, or the suspension for a period specified by the Minister or an authorised body, of an approval granted under subsection (1) (including one that is granted before the date of commencement of the regulations) for non-compliance with a condition of the approval, and for any revocation to take effect from any date, including (if it is just and reasonable to do so) —(i)

a date before the date of the non-compliance with the condition; or

(ii)

if the condition is to be complied with over a period of time, before the date of commencement of that period; and[Act 35 of 2024 wef 27/11/2024]

(d)

make provision generally for giving full effect to or for carrying out the purposes of this section.[2/2016; 45/2018; 32/2019]

(4A) To avoid doubt, where —(a)

an exemption had been allowed under this section on the income of any approved person or person (including a company), trustee, partner, taxable entity, 1st tier SPV, 2nd tier SPV or eligible SPV (each called X);

(b)

the exemption would not have been allowed had a person, fund or structure not been approved under subsection (1) on the date the income accrued to or was derived or received by X; and

(c)

the approval is revoked under regulations made under subsection (4)(cc) with effect from or before that date,

the Comptroller may make an assessment or additional assessment under section 74 on X.

[Act 35 of 2024 wef 27/11/2024]

(4B) Where the approval of a person, fund or structure under subsection (1) is suspended pursuant to regulations made under subsection (4)(cc), the person, fund or structure is treated as not approved under subsection (1) during the period of the suspension.[Act 35 of 2024 wef 27/11/2024]

(5) In this section —“1st tier SPV”, in relation to a master‑feeder fund‑SPV structure or a master fund‑SPV structure, means a special purpose vehicle wholly‑owned by the master fund of the structure;

“2nd tier SPV”, in relation to a master‑feeder fund‑SPV structure or a master fund‑SPV structure, means a special purpose vehicle wholly‑owned by a 1st tier SPV of the structure;

“approved” means approved by the Minister or an authorised body;[Act 41 of 2020 wef 06/12/2022]

“approved person” means —(a)

any approved person (not being an individual, a body of persons or a Hindu joint family);

(b)

any partner of an approved partnership (including a limited partnership and a limited liability partnership);

(c)

any trustee of an approved trust fund; or

(d)

the taxable entity of an approved investment vehicle that is not a legal entity;

“designated unit trust” means any designated unit trust within the meaning of section 35(14) and whose income does not form part of the statutory income of its trustee by reason of section 35(12);

“eligible SPV”, in relation to a master‑feeder fund‑SPV structure or a master fund‑SPV structure, means a special purpose vehicle where the net gains, profits or other benefits of all investments held by the vehicle are to go (whether directly or indirectly) to the master fund of the structure, or the master fund and one or more of the following:(a)

a prescribed person under section 13D;

(b)

an approved company under section 13O;

(ba)

an approved limited partnership under section 13OA;[Act 35 of 2024 wef 01/01/2025]

(c)

an approved person, or an approved master fund, an approved feeder fund, an approved 1st tier SPV, an approved 2nd tier SPV or an approved eligible SPV of any structure mentioned in subsection (1);

(d)

a prescribed sovereign fund entity, an approved foreign government-owned entity, a prescribed international organisation or an approved international organisation under section 13V;[Act 25 of 2025 wef 07/02/2024]

(e)

a person (excluding an individual and a Hindu joint family) —(i)

that is not resident in Singapore;

(ii)

that does not have a permanent establishment in Singapore (other than a fund manager);

(iii)

that does not carry on a business in Singapore;

(iv)

that is not set up solely for the purpose of avoiding or reducing the payment of any tax or penalty under this Act; and

(v)

that carries on outside Singapore substantial business activity for a genuine commercial reason;

(f)

a trust fund —(i)

the trustee of which is not resident in Singapore or a citizen of Singapore;

(ii)

the trustee of which does not (in its capacity as such trustee) have a permanent establishment in Singapore other than a fund manager for that trust fund;

(iii)

the trustee of which does not carry on any business in Singapore other than acting as such trustee;

(iv)

the trustee of which (in its capacity as such trustee) carries on outside Singapore substantial business activity for a genuine commercial reason; and

(v)

that is not set up solely for the purpose of avoiding or reducing the payment of any tax or penalty under this Act;

(g)

a partnership (including a limited partnership and a limited liability partnership) —(i)

none of the partners of which is resident in Singapore;

(ii)

that does not have a permanent establishment in Singapore (other than a fund manager);

(iii)

that does not carry on a business in Singapore;

(iv)

that is not set up solely for the purpose of avoiding or reducing the payment of any tax or penalty under this Act; and

(v)

that carries on outside Singapore substantial business activity for a genuine commercial reason;

(h)

an investment vehicle that is not a legal person —(i)

the taxable entity of which is the custodian of investments held by it;

(ii)

the taxable entity of which is not a resident in Singapore or a citizen of Singapore;

(iii)

the taxable entity of which (in its capacity as custodian of investments held by the investment vehicle) does not have a permanent establishment in Singapore other than a fund manager for that investment vehicle;

(iv)

the taxable entity of which does not carry on any business in Singapore other than acting as such custodian;

(v)

the taxable entity of which carries on outside Singapore substantial business activity for a genuine commercial reason; and

(vi)

that is not set up solely for the purpose of avoiding or reducing the payment of any tax or penalty under this Act;

“feeder fund” means an investment vehicle (whether or not a legal entity) that invests its funds, or whose funds are invested, substantially and directly through a single master fund;

“master‑feeder fund structure” means an arrangement comprising one or more feeder funds and the master fund through which the funds of the feeder fund or funds are substantially and directly invested;

“master‑feeder fund‑SPV structure” means an arrangement comprising —(a)

one or more feeder funds;

(b)

the master fund through which the funds of the feeder fund or funds are substantially and directly invested; and

(c)

one or more SPVs;

“master fund‑SPV structure” means an arrangement comprising —(a)

a master fund; and

(b)

one or more SPVs;

“master fund” —(a)

in relation to a master fund‑SPV structure or master‑feeder fund‑SPV structure, means a company, a trust fund or a limited partnership; or

(b)

in relation to a master‑feeder fund structure, means an investment vehicle (whether or not a legal entity),

that enables investors to invest funds in one or more underlying investments that are managed by a fund manager;

“real estate investment trust” has the meaning given by section 43(10);

“special purpose vehicle” or “SPV” —(a)

in relation to a master‑feeder fund‑SPV structure, means an investment vehicle whose only activity is the holding of investments for other investment vehicles or persons which must include the master and feeder funds of the structure; or

(b)

in relation to a master fund‑SPV structure, means an investment vehicle whose only activity is the holding of investments for other investment vehicles or persons which must include the master fund of the structure;

“taxable entity”, in relation to an investment vehicle (including a master fund, a feeder fund and an SPV) that is not a legal entity, means the person to whom income from the investment vehicle accrues;

“trust fund” does not include any trust that is a pension or provident fund approved by the Comptroller under section 5, designated unit trust and real estate investment trust.[37/2014; 2/2016; 45/2018; 32/2019]

(6) The following approvals may only be granted on or after 20 February 2018:(a)

the approval, for the purposes of the definition of “approved person” in subsection (5), of —(i)

a person other than a company;

(ii)

a partnership, including a limited liability partnership but excluding a limited partnership; or

(iii)

an investment vehicle that is not a legal entity (other than a trust fund);

(b)

the approval, for the purpose of subsection (1)(b), of any of the following as a master fund or feeder fund:(i)

a person that is not a company;

(ii)

a partnership, including a limited liability partnership but excluding a limited partnership;

(iii)

an investment vehicle that is not a legal entity (other than a trust fund).[13X

[45/2018; 32/2019]

—(1) Subject to such conditions as may be prescribed by regulations, or specified in the letter of approval of the person, master fund, feeder fund, SPV, master‑feeder fund structure, master‑feeder fund‑SPV structure or master fund‑SPV structure, or specified from time to time by the Minister or an authorised body and either notified to the holder of the letter of approval or published in a manner that the Minister or authorised body reasonably believes will bring the conditions to the notice of the holder of the letter of approval, there is exempt from tax such income as the Minister may by regulations prescribe of —(a)

an approved person arising from funds managed in Singapore by a fund manager;

(b)

in relation to an approved master‑feeder fund structure —(i)

a person (not being an individual, a body of persons or a Hindu joint family) that is an approved master fund or an approved feeder fund of the structure;

(ii)

a partner of a partnership (including a limited partnership and a limited liability partnership), where the partnership is the approved master fund or an approved feeder fund of the structure;

(iii)

a trustee of a trust fund where the trust fund is the approved master fund or an approved feeder fund of the structure; and

(iv)

a taxable entity in relation to the approved master fund or an approved feeder fund of the structure, where the master fund or feeder fund is not a legal entity,

arising from funds of the master fund or any feeder fund of that structure, that are managed in Singapore by a fund manager;

(c)

in relation to an approved master‑feeder fund‑SPV structure —(i)

a company, a trustee of a trust fund or a partner of a limited partnership, where the company, trust fund or limited partnership is the approved master fund or an approved feeder fund of the structure;

(ia)

a person (not being a company, an individual or a Hindu joint family) that is an approved feeder fund of the structure;

(ib)

a partner of a partnership (excluding a limited partnership but including a limited liability partnership), where the partnership is an approved feeder fund of the structure;

(ic)

a taxable entity in relation to an approved feeder fund of the structure, where the feeder fund is not a legal entity;

(ii)

an approved 1st tier SPV of the structure;

(iii)

an approved 2nd tier SPV of the structure;

(iv)

an approved eligible SPV of the structure, where the eligible SPV is not one mentioned in sub‑paragraphs (v), (vi) and (vii);

(v)

a partner of an approved eligible SPV of the structure, where the eligible SPV is a partnership (including a limited partnership and a limited liability partnership);

(vi)

the trustee of an approved eligible SPV of the structure, where the eligible SPV is a trust fund; and

(vii)

the taxable entity of an approved eligible SPV of the structure, where the eligible SPV is not a legal entity,

arising from funds of —

(viii)

the master fund;

(ix)

any feeder fund; or

(x)

any approved eligible SPV,

of that structure, that are managed in Singapore by a fund manager; or

[Act 33 of 2022 wef 19/02/2019]

(d)

in relation to an approved master fund‑SPV structure —(i)

a company, a trustee of a trust fund or a partner of a limited partnership, where the company, trust fund or limited partnership is the approved master fund of the structure;

(ii)

an approved 1st tier SPV of the structure;

(iii)

an approved 2nd tier SPV of the structure;

(iv)

an approved eligible SPV of the structure, where the eligible SPV is not one mentioned in sub‑paragraphs (v), (vi) and (vii);

(v)

a partner of an approved eligible SPV of the structure, where the eligible SPV is a partnership (including a limited partnership and a limited liability partnership);

(vi)

the trustee of an approved eligible SPV of the structure, where the eligible SPV is a trust fund; and

(vii)

the taxable entity of an approved eligible SPV of the structure, where the eligible SPV is not a legal entity,

arising from funds of the master fund or of any approved eligible SPV of that structure, that are managed in Singapore by a fund manager.

[2/2016; 45/2018; 32/2019]

[Act 33 of 2022 wef 19/02/2019]

[Act 35 of 2024 wef 17/02/2024]

(2) Approval under subsection (1)(a) may be granted during the period from 1 April 2009 to 31 December 2029 (both dates inclusive).[37/2014; 32/2019]

[Act 35 of 2024 wef 27/11/2024]

(2A) Approval under subsection (1)(b) may be granted during the period from 7 July 2010 to 31 December 2029 (both dates inclusive).[37/2014; 32/2019]

[Act 35 of 2024 wef 27/11/2024]

(2B) Approval under subsection (1)(c)(i) and (d)(i) may be granted during the period from 1 April 2015 to 31 December 2029 (both dates inclusive).[32/2019]

[Act 35 of 2024 wef 27/11/2024]

(2C) Approval under subsection (1)(c)(ia), (ib) and (ic) may be granted during the period from 20 February 2018 to 31 December 2029 (both dates inclusive).[32/2019]

[Act 35 of 2024 wef 27/11/2024]

(2D) Approval under subsection (1)(c)(ii) and (iii) and (d)(ii) and (iii) may be granted during the period from 1 April 2015 to 18 February 2019 (both dates inclusive).[32/2019]

(2E) Approval under subsection (1)(c)(iv), (v), (vi) and (vii) and (d)(iv), (v), (vi) and (vii) may be granted during the period from 19 February 2019 to 31 December 2029 (both dates inclusive).[32/2019]

[Act 35 of 2024 wef 27/11/2024]

(2F) An approval under subsection (1) is subject to such conditions as the Minister or an authorised body may impose.[Act 35 of 2024 wef 17/02/2024]

(2G) The Minister or an authorised body may at any time add, vary or delete a condition of an approval under subsection (2F), including (to avoid doubt) an approval given before the date of commencement of section 11(e) of the Income Tax (Amendment) Act 2024.[Act 35 of 2024 wef 27/11/2024]

(2H) Any addition, variation or deletion of a condition under subsection (2G) must be given to the holder of the letter of approval or published in a manner that the Minister or authorised body reasonably believes will bring the addition, variation or deletion to the attention of the holder of the approval.[Act 35 of 2024 wef 27/11/2024]

(3) Where the income of any approved person or person (including a company), trustee, partner, taxable entity, 1st tier SPV, 2nd tier SPV or eligible SPV referred to in subsection (1)(b), (c) or (d) is not exempt from tax under this section, sections 13C, 13D, 13O and 13OA do not apply to that income despite anything in those provisions.[2/2016; 45/2018; 32/2019]

[Act 35 of 2024 wef 01/01/2025]

(4) Regulations made under subsection (1) may —(a)

provide for the determination of the amount of income of any approved person or person (including a company), trustee, partner, taxable entity, 1st tier SPV, 2nd tier SPV or eligible SPV referred to in subsection (1)(b), (c) or (d) to be exempt from tax;

(b)

provide for the deduction of expenses, allowances and losses of any approved person or person (including a company), trustee, partner, taxable entity, 1st tier SPV, 2nd tier SPV or eligible SPV referred to in subsection (1)(b), (c) or (d) otherwise than in accordance with this Act;

(c)

where the approved person is a partner of an approved partnership (including a limited partnership and a limited liability partnership), provide for the recovery of tax from the partner in a case where the exemption ought not to have been allowed to the partner due to non‑compliance with any condition imposed on the partnership, including the deeming of a specified amount as income of the partner for the year of assessment in which the Comptroller discovers the non‑compliance of the condition;

(ca)

provide for the recovery of tax from a person (including a company), trustee, taxable entity, 1st tier SPV, 2nd tier SPV or eligible SPV referred to in subsection (1)(b), (c) or (d) in a case where the exemption ought not to have been allowed to the person due to non‑compliance with any condition imposed on the approved master‑feeder fund structure, approved master‑feeder fund‑SPV structure or approved master fund‑SPV structure, as the case may be;

(cb)

provide for the recovery of tax from a partner of a partnership (including a limited partnership and a limited liability partnership) referred to in subsection (1)(b), (c) or (d) in a case where the exemption ought not to have been allowed to that partner due to non‑compliance with any condition imposed on the approved master‑feeder fund structure, approved master‑feeder fund‑SPV structure or approved master fund‑SPV structure (as the case may be), including the deeming of a specified amount as income of the partner for the year of assessment in which the Comptroller discovers the non‑compliance with the condition; [Act 35 of 2024 wef 27/11/2024]

(cc)

provide for the revocation, or the suspension for a period specified by the Minister or an authorised body, of an approval granted under subsection (1) (including one that is granted before the date of commencement of the regulations) for non-compliance with a condition of the approval, and for any revocation to take effect from any date, including (if it is just and reasonable to do so) —(i)

a date before the date of the non-compliance with the condition; or

(ii)

if the condition is to be complied with over a period of time, before the date of commencement of that period; and[Act 35 of 2024 wef 27/11/2024]

(d)

make provision generally for giving full effect to or for carrying out the purposes of this section.[2/2016; 45/2018; 32/2019]

(4A) To avoid doubt, where —(a)

an exemption had been allowed under this section on the income of any approved person or person (including a company), trustee, partner, taxable entity, 1st tier SPV, 2nd tier SPV or eligible SPV (each called X);

(b)

the exemption would not have been allowed had a person, fund or structure not been approved under subsection (1) on the date the income accrued to or was derived or received by X; and

(c)

the approval is revoked under regulations made under subsection (4)(cc) with effect from or before that date,

the Comptroller may make an assessment or additional assessment under section 74 on X.

[Act 35 of 2024 wef 27/11/2024]

(4B) Where the approval of a person, fund or structure under subsection (1) is suspended pursuant to regulations made under subsection (4)(cc), the person, fund or structure is treated as not approved under subsection (1) during the period of the suspension.[Act 35 of 2024 wef 27/11/2024]

(5) In this section —“1st tier SPV”, in relation to a master‑feeder fund‑SPV structure or a master fund‑SPV structure, means a special purpose vehicle wholly‑owned by the master fund of the structure;

“2nd tier SPV”, in relation to a master‑feeder fund‑SPV structure or a master fund‑SPV structure, means a special purpose vehicle wholly‑owned by a 1st tier SPV of the structure;

“approved” means approved by the Minister or an authorised body;[Act 41 of 2020 wef 06/12/2022]

“approved person” means —(a)

any approved person (not being an individual, a body of persons or a Hindu joint family);

(b)

any partner of an approved partnership (including a limited partnership and a limited liability partnership);

(c)

any trustee of an approved trust fund; or

(d)

the taxable entity of an approved investment vehicle that is not a legal entity;

“designated unit trust” means any designated unit trust within the meaning of section 35(14) and whose income does not form part of the statutory income of its trustee by reason of section 35(12);

“eligible SPV”, in relation to a master‑feeder fund‑SPV structure or a master fund‑SPV structure, means a special purpose vehicle where the net gains, profits or other benefits of all investments held by the vehicle are to go (whether directly or indirectly) to the master fund of the structure, or the master fund and one or more of the following:(a)

a prescribed person under section 13D;

(b)

an approved company under section 13O;

(ba)

an approved limited partnership under section 13OA;[Act 35 of 2024 wef 01/01/2025]

(c)

an approved person, or an approved master fund, an approved feeder fund, an approved 1st tier SPV, an approved 2nd tier SPV or an approved eligible SPV of any structure mentioned in subsection (1);

(d)

a prescribed sovereign fund entity, an approved foreign government-owned entity, a prescribed international organisation or an approved international organisation under section 13V;[Act 25 of 2025 wef 07/02/2024]

(e)

a person (excluding an individual and a Hindu joint family) —(i)

that is not resident in Singapore;

(ii)

that does not have a permanent establishment in Singapore (other than a fund manager);

(iii)

that does not carry on a business in Singapore;

(iv)

that is not set up solely for the purpose of avoiding or reducing the payment of any tax or penalty under this Act; and

(v)

that carries on outside Singapore substantial business activity for a genuine commercial reason;

(f)

a trust fund —(i)

the trustee of which is not resident in Singapore or a citizen of Singapore;

(ii)

the trustee of which does not (in its capacity as such trustee) have a permanent establishment in Singapore other than a fund manager for that trust fund;

(iii)

the trustee of which does not carry on any business in Singapore other than acting as such trustee;

(iv)

the trustee of which (in its capacity as such trustee) carries on outside Singapore substantial business activity for a genuine commercial reason; and

(v)

that is not set up solely for the purpose of avoiding or reducing the payment of any tax or penalty under this Act;

(g)

a partnership (including a limited partnership and a limited liability partnership) —(i)

none of the partners of which is resident in Singapore;

(ii)

that does not have a permanent establishment in Singapore (other than a fund manager);

(iii)

that does not carry on a business in Singapore;

(iv)

that is not set up solely for the purpose of avoiding or reducing the payment of any tax or penalty under this Act; and

(v)

that carries on outside Singapore substantial business activity for a genuine commercial reason;

(h)

an investment vehicle that is not a legal person —(i)

the taxable entity of which is the custodian of investments held by it;

(ii)

the taxable entity of which is not a resident in Singapore or a citizen of Singapore;

(iii)

the taxable entity of which (in its capacity as custodian of investments held by the investment vehicle) does not have a permanent establishment in Singapore other than a fund manager for that investment vehicle;

(iv)

the taxable entity of which does not carry on any business in Singapore other than acting as such custodian;

(v)

the taxable entity of which carries on outside Singapore substantial business activity for a genuine commercial reason; and

(vi)

that is not set up solely for the purpose of avoiding or reducing the payment of any tax or penalty under this Act;

“feeder fund” means an investment vehicle (whether or not a legal entity) that invests its funds, or whose funds are invested, substantially and directly through a single master fund;

“master‑feeder fund structure” means an arrangement comprising one or more feeder funds and the master fund through which the funds of the feeder fund or funds are substantially and directly invested;

“master‑feeder fund‑SPV structure” means an arrangement comprising —(a)

one or more feeder funds;

(b)

the master fund through which the funds of the feeder fund or funds are substantially and directly invested; and

(c)

one or more SPVs;

“master fund‑SPV structure” means an arrangement comprising —(a)

a master fund; and

(b)

one or more SPVs;

“master fund” —(a)

in relation to a master fund‑SPV structure or master‑feeder fund‑SPV structure, means a company, a trust fund or a limited partnership; or

(b)

in relation to a master‑feeder fund structure, means an investment vehicle (whether or not a legal entity),

that enables investors to invest funds in one or more underlying investments that are managed by a fund manager;

“real estate investment trust” has the meaning given by section 43(10);

“special purpose vehicle” or “SPV” —(a)

in relation to a master‑feeder fund‑SPV structure, means an investment vehicle whose only activity is the holding of investments for other investment vehicles or persons which must include the master and feeder funds of the structure; or

(b)

in relation to a master fund‑SPV structure, means an investment vehicle whose only activity is the holding of investments for other investment vehicles or persons which must include the master fund of the structure;

“taxable entity”, in relation to an investment vehicle (including a master fund, a feeder fund and an SPV) that is not a legal entity, means the person to whom income from the investment vehicle accrues;

“trust fund” does not include any trust that is a pension or provident fund approved by the Comptroller under section 5, designated unit trust and real estate investment trust.[37/2014; 2/2016; 45/2018; 32/2019]

(6) The following approvals may only be granted on or after 20 February 2018:(a)

the approval, for the purposes of the definition of “approved person” in subsection (5), of —(i)

a person other than a company;

(ii)

a partnership, including a limited liability partnership but excluding a limited partnership; or

(iii)

an investment vehicle that is not a legal entity (other than a trust fund);

(b)

the approval, for the purpose of subsection (1)(b), of any of the following as a master fund or feeder fund:(i)

a person that is not a company;

(ii)

a partnership, including a limited liability partnership but excluding a limited partnership;

(iii)

an investment vehicle that is not a legal entity (other than a trust fund).[13X

[45/2018; 32/2019]