§ 43C — Exemption and concessionary rate of tax for insurance and reinsurance business

43C.—(1) Despite section 43, the Minister may make regulations —(a)

to provide for tax at the rate of 10% to be levied and paid for each year of assessment upon such income as the Minister may specify that is derived before 1 July 2021 by an approved insurer, whose approval is granted before 1 June 2017, from offshore life business within the meaning of section 26, or the business (other than the business of life assurance) of insuring and reinsuring offshore risks;

(aa)

to provide for tax at the rate specified in the first column of the following table, to be levied and paid for each year of assessment upon such income as the Minister may specify that is derived by an approved insurer set out opposite that rate in the second column of the table, from the reinsurance of liabilities under policies relating to life business as defined in section 3(1)(a) of the Insurance Act 1966, or such description of general business within the meaning of section 3(1)(b) of that Act, as may be prescribed:Tax rate

Approved insurer

10%

An approved insurer whose approval is granted between 1 June 2017 and 18 February 2025 (both dates inclusive)

10% or 15%

An approved insurer whose approval is granted on or after 19 February 2025

[Act 25 of 2025 wef 01/01/2025]

(ab)

to provide for tax at the rate of 10% to be levied and paid for each year of assessment upon such income as the Minister may specify that is derived on or after 1 July 2021 by an approved insurer whose approval is granted before 1 June 2017, from —(i)

the reinsurance of liabilities under policies relating to life business as defined in section 3(1)(a) of the Insurance Act 1966; or

(ii)

such description of general business as defined in section 3(1)(b) of that Act, as may be prescribed;

(b)

to provide for exemption from tax of such income as the Minister may specify that is derived from insurance and reinsurance business by the following:(i)

an approved specialised insurer whose approval is granted before 1 September 2016;

(ii)

an approved captive insurer whose approval is granted before 1 April 2018;

(c)

to provide for tax at the rate specified in the first column of the following table, to be levied and paid for each year of assessment upon such income as the Minister may specify that is derived from insurance and reinsurance business by an approved insurer set out opposite that rate in the second column of the table:Tax rate

Approved insurer

5%

An approved specialised insurer whose approval is granted between 1 September 2016 and 31 August 2019 (both dates inclusive), and who had not been approved as such at any time before the date of the approval

8%

An approved specialised insurer whose approval is granted between 1 September 2019 and 31 August 2021 (both dates inclusive), and who had not been approved as such at any time before the date of the approval

10%

(i)

An approved specialised insurer whose approval is granted between 1 September 2016 and 31 August 2021 (both dates inclusive), and who had been approved as such at any time before the date of the firstmentioned approval

(ii)

An approved captive insurer whose approval is granted between 1 April 2018 and 18 February 2025 (both dates inclusive)

10% or 15%

An approved captive insurer whose approval is granted on or after 19 February 2025

[Act 25 of 2025 wef 01/01/2025]

(d)

to provide for exemption from tax of such income as the Minister may specify that is derived by an approved insurer whose approval is granted before 1 April 2016, from marine hull and liability insurance and reinsurance business;

(e)

to provide for tax at the rate specified in the first column of the following table, to be levied and paid for each year of assessment upon such income as the Minister may specify that is derived from marine hull and liability insurance and reinsurance business by an approved insurer set out opposite that rate in the second column of the table:Tax rate

Approved insurer

5%

An approved insurer whose approval was granted between 19 February 2011 and 31 March 2016 (both dates inclusive), and who had been approved as such at any time before the date of the firstmentioned approval

10%

An approved insurer whose approval is granted between 1 April 2016 and 31 March 2020 (both dates inclusive)

(f)

to provide for the deduction (otherwise than in accordance with this Act), from the income mentioned in paragraphs (a) to (e), of allowances under section 19, 19A, 20, 21, 22 or 23, expenses, losses and donations allowable under this Act, including deduction of these allowances, expenses, losses and donations in such manner and to such extent as the Comptroller may determine;

(g)

to provide for the period of each approval, and the conditions subject to which a specified insurer may be or may continue to be approved; and

(h)

to provide for such matters as the Minister may consider necessary or expedient for carrying out the purposes under paragraphs (a) to (g).[34/2016; 39/2017; 32/2019; 41/2020; 27/2021]

(2) No approval may be granted to an insurer for the purpose of paragraph (a), (aa), (b), (c), (d) or (e) of subsection (1) on or after the date prescribed in the regulations for that paragraph.[34/2016; 39/2017]

(2A) Regulations made under subsection (1)(aa) or (c) to provide for tax at the rate of 15% to be levied and paid for each year of assessment upon income mentioned in that provision may be made to take effect from (and including) 1 January 2025.[Act 25 of 2025 wef 01/01/2025]

(3) In this section —“approved” means approved by the Minister or an authorised body;[Act 41 of 2020 wef 06/12/2022]

“captive insurer” has the meaning given by section 2 of the Insurance Act 1966;

“insurer” means —(a)

a company licensed under the Insurance Act 1966 to carry on insurance business in Singapore; or

(b)

a person (including a partnership), other than an individual, permitted under the Insurance Act 1966 to carry on insurance business in Singapore under a foreign insurer scheme;

“marine hull and liability insurance and reinsurance business” means the business of insuring and reinsuring risks involving marine hull and liability but excludes cargo, energy and aviation risks;

“specialised insurer” means an insurer underwriting any of the following insurance risks (whether or not it also underwrites any other type of risk):(a)

terrorism risks;

(b)

political risks;

(c)

energy risks;

(d)

aviation and aerospace risks;

(e)

agriculture risks;

(f)

risks arising from a natural catastrophe.[34/2016; 39/2017]

—(1) Despite section 43, the Minister may make regulations —(a)

to provide for tax at the rate of 10% to be levied and paid for each year of assessment upon such income as the Minister may specify that is derived before 1 July 2021 by an approved insurer, whose approval is granted before 1 June 2017, from offshore life business within the meaning of section 26, or the business (other than the business of life assurance) of insuring and reinsuring offshore risks;

(aa)

to provide for tax at the rate specified in the first column of the following table, to be levied and paid for each year of assessment upon such income as the Minister may specify that is derived by an approved insurer set out opposite that rate in the second column of the table, from the reinsurance of liabilities under policies relating to life business as defined in section 3(1)(a) of the Insurance Act 1966, or such description of general business within the meaning of section 3(1)(b) of that Act, as may be prescribed:Tax rate

Approved insurer

10%

An approved insurer whose approval is granted between 1 June 2017 and 18 February 2025 (both dates inclusive)

10% or 15%

An approved insurer whose approval is granted on or after 19 February 2025

[Act 25 of 2025 wef 01/01/2025]

(ab)

to provide for tax at the rate of 10% to be levied and paid for each year of assessment upon such income as the Minister may specify that is derived on or after 1 July 2021 by an approved insurer whose approval is granted before 1 June 2017, from —(i)

the reinsurance of liabilities under policies relating to life business as defined in section 3(1)(a) of the Insurance Act 1966; or

(ii)

such description of general business as defined in section 3(1)(b) of that Act, as may be prescribed;

(b)

to provide for exemption from tax of such income as the Minister may specify that is derived from insurance and reinsurance business by the following:(i)

an approved specialised insurer whose approval is granted before 1 September 2016;

(ii)

an approved captive insurer whose approval is granted before 1 April 2018;

(c)

to provide for tax at the rate specified in the first column of the following table, to be levied and paid for each year of assessment upon such income as the Minister may specify that is derived from insurance and reinsurance business by an approved insurer set out opposite that rate in the second column of the table:Tax rate

Approved insurer

5%

An approved specialised insurer whose approval is granted between 1 September 2016 and 31 August 2019 (both dates inclusive), and who had not been approved as such at any time before the date of the approval

8%

An approved specialised insurer whose approval is granted between 1 September 2019 and 31 August 2021 (both dates inclusive), and who had not been approved as such at any time before the date of the approval

10%

(i)

An approved specialised insurer whose approval is granted between 1 September 2016 and 31 August 2021 (both dates inclusive), and who had been approved as such at any time before the date of the firstmentioned approval

(ii)

An approved captive insurer whose approval is granted between 1 April 2018 and 18 February 2025 (both dates inclusive)

10% or 15%

An approved captive insurer whose approval is granted on or after 19 February 2025

[Act 25 of 2025 wef 01/01/2025]

(d)

to provide for exemption from tax of such income as the Minister may specify that is derived by an approved insurer whose approval is granted before 1 April 2016, from marine hull and liability insurance and reinsurance business;

(e)

to provide for tax at the rate specified in the first column of the following table, to be levied and paid for each year of assessment upon such income as the Minister may specify that is derived from marine hull and liability insurance and reinsurance business by an approved insurer set out opposite that rate in the second column of the table:Tax rate

Approved insurer

5%

An approved insurer whose approval was granted between 19 February 2011 and 31 March 2016 (both dates inclusive), and who had been approved as such at any time before the date of the firstmentioned approval

10%

An approved insurer whose approval is granted between 1 April 2016 and 31 March 2020 (both dates inclusive)

(f)

to provide for the deduction (otherwise than in accordance with this Act), from the income mentioned in paragraphs (a) to (e), of allowances under section 19, 19A, 20, 21, 22 or 23, expenses, losses and donations allowable under this Act, including deduction of these allowances, expenses, losses and donations in such manner and to such extent as the Comptroller may determine;

(g)

to provide for the period of each approval, and the conditions subject to which a specified insurer may be or may continue to be approved; and

(h)

to provide for such matters as the Minister may consider necessary or expedient for carrying out the purposes under paragraphs (a) to (g).[34/2016; 39/2017; 32/2019; 41/2020; 27/2021]

(2) No approval may be granted to an insurer for the purpose of paragraph (a), (aa), (b), (c), (d) or (e) of subsection (1) on or after the date prescribed in the regulations for that paragraph.[34/2016; 39/2017]

(2A) Regulations made under subsection (1)(aa) or (c) to provide for tax at the rate of 15% to be levied and paid for each year of assessment upon income mentioned in that provision may be made to take effect from (and including) 1 January 2025.[Act 25 of 2025 wef 01/01/2025]

(3) In this section —“approved” means approved by the Minister or an authorised body;[Act 41 of 2020 wef 06/12/2022]

“captive insurer” has the meaning given by section 2 of the Insurance Act 1966;

“insurer” means —(a)

a company licensed under the Insurance Act 1966 to carry on insurance business in Singapore; or

(b)

a person (including a partnership), other than an individual, permitted under the Insurance Act 1966 to carry on insurance business in Singapore under a foreign insurer scheme;

“marine hull and liability insurance and reinsurance business” means the business of insuring and reinsuring risks involving marine hull and liability but excludes cargo, energy and aviation risks;

“specialised insurer” means an insurer underwriting any of the following insurance risks (whether or not it also underwrites any other type of risk):(a)

terrorism risks;

(b)

political risks;

(c)

energy risks;

(d)

aviation and aerospace risks;

(e)

agriculture risks;

(f)

risks arising from a natural catastrophe.[34/2016; 39/2017]