§ 13V — Exemption of certain income of prescribed sovereign fund entity, approved foreign government-owned entity, and prescribed or approved international organisation

13V.—(1) There is exempt from tax such income as the Minister may by regulations prescribe of —(a)

a prescribed sovereign fund entity arising from its funds that are managed in Singapore by an approved foreign government‑owned entity;[Act 35 of 2024 wef 07/02/2024]

(b)

an approved foreign government‑owned entity arising from its funds that are managed in Singapore, and from managing in Singapore the funds of, or providing in Singapore any investment advisory service to, a prescribed sovereign fund entity;[Act 35 of 2024 wef 07/02/2024]

(c)

a prescribed sovereign fund entity or a prescribed international organisation arising on or after 7 February 2024 from its funds that are managed in Singapore by an approved foreign government‑owned entity or an approved international organisation; and[Act 35 of 2024 wef 07/02/2024]

(d)

an approved foreign government‑owned entity or an approved international organisation arising on or after 7 February 2024 from —(i)

its funds that are managed in Singapore; and

(ii)

managing in Singapore on or after that date the funds of, or providing in Singapore on or after that date any investment advisory service to, a prescribed sovereign fund entity or a prescribed international organisation.[Act 35 of 2024 wef 07/02/2024]

(2) The Minister or an authorised body may, at any time between 1 April 2010 and 31 December 2029 (both dates inclusive), approve a foreign government‑owned entity or an international organisation for the purpose of subsection (1).[37/2014; 32/2019]

[Act 41 of 2020 wef 06/12/2022]

[Act 35 of 2024 wef 07/02/2024]

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

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

provide for the period of each approval, and that the conditions to which any approval is subject may be stated in the letter of approval issued to the foreign government‑owned entity or international organisation;[Act 35 of 2024 wef 07/02/2024]

(aa)

provide for renewal of an approval;

(b)

provide for the determination of the amount of income of a prescribed sovereign fund entity, an approved foreign government-owned entity, a prescribed international organisation or an approved international organisation that is exempt from tax;[Act 35 of 2024 wef 07/02/2024]

(c)

provide for the deduction of expenses, allowances and losses of a prescribed sovereign fund entity, an approved foreign government-owned entity, a prescribed international organisation or an approved international organisation otherwise than in accordance with this Act; and[Act 35 of 2024 wef 07/02/2024]

(d)

make provision generally for giving full effect to or for carrying out the purposes of this section.[37/2014]

(4) In this section —(a)

“foreign government‑owned entity”, in relation to income derived before 7 February 2024, means —(i)

an entity wholly and beneficially owned (whether directly or indirectly) by the government or other public authority of a foreign country;

(ii)

an entity that is incorporated, formed or established by the government or other public authority of a foreign country either directly or indirectly through one or more intermediate entities;

(iii)

an entity that is incorporated, formed or established by the law of a foreign country and that is not a public authority of that foreign country; or

(iv)

an entity that is incorporated, formed or established by an entity mentioned in sub‑paragraph (iii) either directly or indirectly through one or more intermediate entities,

and whose principal activity is to manage the entity’s own funds or the funds of a prescribed sovereign fund entity as defined in subsection (5)(a); and

(b)

“foreign government-owned entity”, in relation to income derived on or after 7 February 2024, means —(i)

an entity wholly and beneficially owned (whether directly or indirectly) by the government or other public authority of one or more foreign countries;

(ii)

an entity that is incorporated, formed or established by the government or other public authority of one or more foreign countries, either directly or indirectly through one or more intermediate entities;

(iii)

an entity that is incorporated, formed or established by the law of a foreign country and that is not a public authority of that foreign country;

(iv)

an entity that is incorporated, formed or established by an entity mentioned in sub‑paragraph (iii) either directly or indirectly through one or more intermediate entities; or

(v)

an entity in which the government or other public authority of one or more foreign countries beneficially owns (directly or indirectly) a percentage of the issued securities of the entity,

and whose principal activity is to manage the entity’s own funds or the funds of a prescribed sovereign fund entity (as defined in subsection (5)(b)) or a prescribed international organisation.

[Act 35 of 2024 wef 07/02/2024]

(5) In this section —(a)

“sovereign fund entity”, in relation to income derived before 7 February 2024, means —(i)

the government or other public authority of a foreign country;

(ii)

an entity wholly and beneficially owned by the government or other public authority of a foreign country;

(iii)

an entity that is incorporated, formed or established by the government or other public authority of a foreign country either directly or indirectly through one or more intermediate entities;

(iv)

an entity that is incorporated, formed or established by the law of a foreign country and that is not a public authority of that foreign country; or

(v)

an entity that is incorporated, formed or established by an entity mentioned in sub‑paragraph (iv) either directly or indirectly through one or more intermediate entities,

and whose funds (which may include the reserves of the government and any pension or provident fund of that country) are managed by an approved foreign government‑owned entity as defined by subsection (4)(a);

(b)

“sovereign fund entity”, in relation to income derived on or after 7 February 2024, means —(i)

the government or other public authority of a foreign country;

(ii)

an entity wholly and beneficially owned by the government or other public authority of one or more foreign countries;

(iii)

an entity that is incorporated, formed or established by the government or other public authority of one or more foreign countries either directly or indirectly through one or more intermediate entities;

(iv)

an entity that is incorporated, formed or established by the law of a foreign country and that is not a public authority of that foreign country; or

(v)

an entity that is incorporated, formed or established by an entity mentioned in sub‑paragraph (iv) either directly or indirectly through one or more intermediate entities,

and whose funds (which may include the reserves of the government and any pension or provident fund of that country or those countries) are managed by an approved foreign government‑owned entity as defined in subsection (4)(b) or an approved international organisation; and

(c)

“prescribed sovereign fund entity” means a sovereign fund entity that satisfies such conditions as may be prescribed.[Act 35 of 2024 wef 07/02/2024]

(6) In this section —(a)

“international organisation” means an organisation —(i)

of which 2 or more countries, or the governments of 2 or more countries, are members; or

(ii)

that is constituted by persons representing 2 or more countries, or the governments of 2 or more countries,

and includes —

(iii)

an entity that is incorporated, formed or established by an international organisation (as defined in sub‑paragraph (i) or (ii)), either directly or indirectly through one or more intermediate entities; and

(iv)

an entity in which an international organisation (as defined in sub‑paragraph (i) or (ii)) beneficially owns (directly or indirectly) a percentage of the issued securities of the entity; and

(b)

“prescribed international organisation” means an international organisation that satisfies such conditions as may be prescribed.[13Y

[41/2020]

[Act 35 of 2024 wef 07/02/2024]

—(1) There is exempt from tax such income as the Minister may by regulations prescribe of —(a)

a prescribed sovereign fund entity arising from its funds that are managed in Singapore by an approved foreign government‑owned entity;[Act 35 of 2024 wef 07/02/2024]

(b)

an approved foreign government‑owned entity arising from its funds that are managed in Singapore, and from managing in Singapore the funds of, or providing in Singapore any investment advisory service to, a prescribed sovereign fund entity;[Act 35 of 2024 wef 07/02/2024]

(c)

a prescribed sovereign fund entity or a prescribed international organisation arising on or after 7 February 2024 from its funds that are managed in Singapore by an approved foreign government‑owned entity or an approved international organisation; and[Act 35 of 2024 wef 07/02/2024]

(d)

an approved foreign government‑owned entity or an approved international organisation arising on or after 7 February 2024 from —(i)

its funds that are managed in Singapore; and

(ii)

managing in Singapore on or after that date the funds of, or providing in Singapore on or after that date any investment advisory service to, a prescribed sovereign fund entity or a prescribed international organisation.[Act 35 of 2024 wef 07/02/2024]

(2) The Minister or an authorised body may, at any time between 1 April 2010 and 31 December 2029 (both dates inclusive), approve a foreign government‑owned entity or an international organisation for the purpose of subsection (1).[37/2014; 32/2019]

[Act 41 of 2020 wef 06/12/2022]

[Act 35 of 2024 wef 07/02/2024]

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

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

provide for the period of each approval, and that the conditions to which any approval is subject may be stated in the letter of approval issued to the foreign government‑owned entity or international organisation;[Act 35 of 2024 wef 07/02/2024]

(aa)

provide for renewal of an approval;

(b)

provide for the determination of the amount of income of a prescribed sovereign fund entity, an approved foreign government-owned entity, a prescribed international organisation or an approved international organisation that is exempt from tax;[Act 35 of 2024 wef 07/02/2024]

(c)

provide for the deduction of expenses, allowances and losses of a prescribed sovereign fund entity, an approved foreign government-owned entity, a prescribed international organisation or an approved international organisation otherwise than in accordance with this Act; and[Act 35 of 2024 wef 07/02/2024]

(d)

make provision generally for giving full effect to or for carrying out the purposes of this section.[37/2014]

(4) In this section —(a)

“foreign government‑owned entity”, in relation to income derived before 7 February 2024, means —(i)

an entity wholly and beneficially owned (whether directly or indirectly) by the government or other public authority of a foreign country;

(ii)

an entity that is incorporated, formed or established by the government or other public authority of a foreign country either directly or indirectly through one or more intermediate entities;

(iii)

an entity that is incorporated, formed or established by the law of a foreign country and that is not a public authority of that foreign country; or

(iv)

an entity that is incorporated, formed or established by an entity mentioned in sub‑paragraph (iii) either directly or indirectly through one or more intermediate entities,

and whose principal activity is to manage the entity’s own funds or the funds of a prescribed sovereign fund entity as defined in subsection (5)(a); and

(b)

“foreign government-owned entity”, in relation to income derived on or after 7 February 2024, means —(i)

an entity wholly and beneficially owned (whether directly or indirectly) by the government or other public authority of one or more foreign countries;

(ii)

an entity that is incorporated, formed or established by the government or other public authority of one or more foreign countries, either directly or indirectly through one or more intermediate entities;

(iii)

an entity that is incorporated, formed or established by the law of a foreign country and that is not a public authority of that foreign country;

(iv)

an entity that is incorporated, formed or established by an entity mentioned in sub‑paragraph (iii) either directly or indirectly through one or more intermediate entities; or

(v)

an entity in which the government or other public authority of one or more foreign countries beneficially owns (directly or indirectly) a percentage of the issued securities of the entity,

and whose principal activity is to manage the entity’s own funds or the funds of a prescribed sovereign fund entity (as defined in subsection (5)(b)) or a prescribed international organisation.

[Act 35 of 2024 wef 07/02/2024]

(5) In this section —(a)

“sovereign fund entity”, in relation to income derived before 7 February 2024, means —(i)

the government or other public authority of a foreign country;

(ii)

an entity wholly and beneficially owned by the government or other public authority of a foreign country;

(iii)

an entity that is incorporated, formed or established by the government or other public authority of a foreign country either directly or indirectly through one or more intermediate entities;

(iv)

an entity that is incorporated, formed or established by the law of a foreign country and that is not a public authority of that foreign country; or

(v)

an entity that is incorporated, formed or established by an entity mentioned in sub‑paragraph (iv) either directly or indirectly through one or more intermediate entities,

and whose funds (which may include the reserves of the government and any pension or provident fund of that country) are managed by an approved foreign government‑owned entity as defined by subsection (4)(a);

(b)

“sovereign fund entity”, in relation to income derived on or after 7 February 2024, means —(i)

the government or other public authority of a foreign country;

(ii)

an entity wholly and beneficially owned by the government or other public authority of one or more foreign countries;

(iii)

an entity that is incorporated, formed or established by the government or other public authority of one or more foreign countries either directly or indirectly through one or more intermediate entities;

(iv)

an entity that is incorporated, formed or established by the law of a foreign country and that is not a public authority of that foreign country; or

(v)

an entity that is incorporated, formed or established by an entity mentioned in sub‑paragraph (iv) either directly or indirectly through one or more intermediate entities,

and whose funds (which may include the reserves of the government and any pension or provident fund of that country or those countries) are managed by an approved foreign government‑owned entity as defined in subsection (4)(b) or an approved international organisation; and

(c)

“prescribed sovereign fund entity” means a sovereign fund entity that satisfies such conditions as may be prescribed.[Act 35 of 2024 wef 07/02/2024]

(6) In this section —(a)

“international organisation” means an organisation —(i)

of which 2 or more countries, or the governments of 2 or more countries, are members; or

(ii)

that is constituted by persons representing 2 or more countries, or the governments of 2 or more countries,

and includes —

(iii)

an entity that is incorporated, formed or established by an international organisation (as defined in sub‑paragraph (i) or (ii)), either directly or indirectly through one or more intermediate entities; and

(iv)

an entity in which an international organisation (as defined in sub‑paragraph (i) or (ii)) beneficially owns (directly or indirectly) a percentage of the issued securities of the entity; and

(b)

“prescribed international organisation” means an international organisation that satisfies such conditions as may be prescribed.[13Y

[41/2020]

[Act 35 of 2024 wef 07/02/2024]