§ 43E — Concessionary rate of tax for Finance and Treasury Centre

43E.—(1) Despite section 43, the Minister may by regulations provide that tax at the concessionary rate specified in subsection (1A) is levied and must be paid for each year of assessment upon such income as the Minister may specify of a company derived from —(a)

the operation of its approved Finance and Treasury Centre in respect of such qualifying activities carried out on its own account as may be prescribed; or

(b)

such prescribed qualifying services as may be provided by its approved Finance and Treasury Centre to —(i)

its offices and associated companies outside Singapore; or

(ii)

such of its offices and associated companies in Singapore as are approved on or after 18 February 2005,

and those regulations may provide for the deduction of losses otherwise than in accordance with section 37(3).

[34/2016]

(1A) In subsection (1), the concessionary rate is —(a)

in the case of a Finance and Treasury Centre approved as such on or before 24 March 2016, 10%;[Act 35 of 2024 wef 01/01/2024]

(b)

in the case of a Finance and Treasury Centre approved as such after 24 March 2016 and on or before 16 February 2024, 8%;[Act 35 of 2024 wef 01/01/2024]

(c)

in the case of a Finance and Treasury Centre approved as such on or after 17 February 2024, 8% or 10%, as specified by the Minister or an authorised body to the company; or[Act 35 of 2024 wef 01/01/2024]

(d)

in a case to which subsection (1B) applies, the substituted concessionary rate mentioned in that subsection but only for income derived from (and including) the date specified by the Minister or authorised body to the company for the application of that rate, which may be a date earlier than the notice mentioned in that subsection but not earlier than 1 January 2024.[34/2016]

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

(1B) The Minister or an authorised body may, on or after 17 February 2024, on the Minister’s or authorised body’s own initiative or on the application of the company, by notice to the company substitute the concessionary rate of tax applicable to its approved Finance and Treasury Centre under subsection (1A)(b) or (c) with 8% or 10%, as the case may be.[Act 35 of 2024 wef 01/01/2024]

(2) The concessionary rate of tax mentioned in subsection (1) applies to an approved Finance and Treasury Centre —(a)

in respect of any qualifying service only where the qualifying service and the office or associated company to whom the service is rendered have been approved in relation to that Centre for such concessionary rate; and

(b)

in respect of any qualifying activity only where the qualifying activity has been approved in relation to that Centre for such concessionary rate.[32/2019]

(2A) The Minister or an authorised body may, subject to such conditions as the Minister or authorised body may impose, approve a Finance and Treasury Centre for a company for the purposes of this section.[32/2019]

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

(3) In this section —“approved” means approved by the Minister or an authorised body;[Act 41 of 2020 wef 12/04/2024]

“associated company”, in relation to a company with an approved Finance and Treasury Centre, means a company —(a)

the operations of which are or can be controlled, directly or indirectly, by the company with the approved Centre;

(b)

which controls or can control, directly or indirectly, the operations of the company with the approved Centre; or

(c)

the operations of which are or can be controlled, directly or indirectly, by a person or persons who control or can control, directly or indirectly, the operations of the company with the approved Centre;

“Finance and Treasury Centre” means a division or department of a company which provides treasury, investment or financial services in Singapore for its offices or its associated companies.[34/2016]

(3A) The reference to an authorised body in subsection (1A)(c) is, in a case where the concessionary rate of tax in that provision applicable to the approved Finance and Treasury Centre of a company is specified to the company during the period from 17 February 2024 to 11 April 2024 (both dates inclusive), a reference to a person appointed by the Minister.[Act 25 of 2025 wef 01/01/2024]

(3B) A reference in subsections (1A)(d) and (1B) to an authorised body is, in a case where the notice to substitute the concessionary rate of tax applicable to the approved Finance and Treasury Centre of a company is given to the company during the period from 17 February 2024 to 11 April 2024 (both dates inclusive), a reference to a person appointed by the Minister.[Act 25 of 2025 wef 01/01/2024]

(4) For the purposes of subsection (3), a company is deemed to be an associated company in relation to a company with an approved Finance and Treasury Centre if —(a)

at least 25% of the total number of its issued shares are beneficially owned, directly or indirectly, by the company with the approved Centre; or

(b)

at least 25% of the total number of issued shares of the company with the approved Centre are beneficially owned, directly or indirectly, by the firstmentioned company.

(5) No Finance and Treasury Centre may be approved as an approved Finance and Treasury Centre under this section after 31 December 2026.[43G

[34/2016; 41/2020]

—(1) Despite section 43, the Minister may by regulations provide that tax at the concessionary rate specified in subsection (1A) is levied and must be paid for each year of assessment upon such income as the Minister may specify of a company derived from —(a)

the operation of its approved Finance and Treasury Centre in respect of such qualifying activities carried out on its own account as may be prescribed; or

(b)

such prescribed qualifying services as may be provided by its approved Finance and Treasury Centre to —(i)

its offices and associated companies outside Singapore; or

(ii)

such of its offices and associated companies in Singapore as are approved on or after 18 February 2005,

and those regulations may provide for the deduction of losses otherwise than in accordance with section 37(3).

[34/2016]

(1A) In subsection (1), the concessionary rate is —(a)

in the case of a Finance and Treasury Centre approved as such on or before 24 March 2016, 10%;[Act 35 of 2024 wef 01/01/2024]

(b)

in the case of a Finance and Treasury Centre approved as such after 24 March 2016 and on or before 16 February 2024, 8%;[Act 35 of 2024 wef 01/01/2024]

(c)

in the case of a Finance and Treasury Centre approved as such on or after 17 February 2024, 8% or 10%, as specified by the Minister or an authorised body to the company; or[Act 35 of 2024 wef 01/01/2024]

(d)

in a case to which subsection (1B) applies, the substituted concessionary rate mentioned in that subsection but only for income derived from (and including) the date specified by the Minister or authorised body to the company for the application of that rate, which may be a date earlier than the notice mentioned in that subsection but not earlier than 1 January 2024.[34/2016]

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

(1B) The Minister or an authorised body may, on or after 17 February 2024, on the Minister’s or authorised body’s own initiative or on the application of the company, by notice to the company substitute the concessionary rate of tax applicable to its approved Finance and Treasury Centre under subsection (1A)(b) or (c) with 8% or 10%, as the case may be.[Act 35 of 2024 wef 01/01/2024]

(2) The concessionary rate of tax mentioned in subsection (1) applies to an approved Finance and Treasury Centre —(a)

in respect of any qualifying service only where the qualifying service and the office or associated company to whom the service is rendered have been approved in relation to that Centre for such concessionary rate; and

(b)

in respect of any qualifying activity only where the qualifying activity has been approved in relation to that Centre for such concessionary rate.[32/2019]

(2A) The Minister or an authorised body may, subject to such conditions as the Minister or authorised body may impose, approve a Finance and Treasury Centre for a company for the purposes of this section.[32/2019]

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

(3) In this section —“approved” means approved by the Minister or an authorised body;[Act 41 of 2020 wef 12/04/2024]

“associated company”, in relation to a company with an approved Finance and Treasury Centre, means a company —(a)

the operations of which are or can be controlled, directly or indirectly, by the company with the approved Centre;

(b)

which controls or can control, directly or indirectly, the operations of the company with the approved Centre; or

(c)

the operations of which are or can be controlled, directly or indirectly, by a person or persons who control or can control, directly or indirectly, the operations of the company with the approved Centre;

“Finance and Treasury Centre” means a division or department of a company which provides treasury, investment or financial services in Singapore for its offices or its associated companies.[34/2016]

(3A) The reference to an authorised body in subsection (1A)(c) is, in a case where the concessionary rate of tax in that provision applicable to the approved Finance and Treasury Centre of a company is specified to the company during the period from 17 February 2024 to 11 April 2024 (both dates inclusive), a reference to a person appointed by the Minister.[Act 25 of 2025 wef 01/01/2024]

(3B) A reference in subsections (1A)(d) and (1B) to an authorised body is, in a case where the notice to substitute the concessionary rate of tax applicable to the approved Finance and Treasury Centre of a company is given to the company during the period from 17 February 2024 to 11 April 2024 (both dates inclusive), a reference to a person appointed by the Minister.[Act 25 of 2025 wef 01/01/2024]

(4) For the purposes of subsection (3), a company is deemed to be an associated company in relation to a company with an approved Finance and Treasury Centre if —(a)

at least 25% of the total number of its issued shares are beneficially owned, directly or indirectly, by the company with the approved Centre; or

(b)

at least 25% of the total number of issued shares of the company with the approved Centre are beneficially owned, directly or indirectly, by the firstmentioned company.

(5) No Finance and Treasury Centre may be approved as an approved Finance and Treasury Centre under this section after 31 December 2026.[43G

[34/2016; 41/2020]