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§ 43U — Concessionary rate of tax for shipping‑related support services
43U.—(1) Despite section 43, tax at the rate of 10% is to be levied and paid for each year of assessment upon the amount of income in subsection (1A) of an approved company derived on or after the service approval date and during the period of its approval under subsection (2) (but not any extended period of its approval under subsection (5A)), from providing in or from Singapore any shipping‑related support service approved for it under subsection (2A).[2/2016]
(1A) In subsection (1), the amount of the income is that which exceeds the base amount calculated in accordance with subsection (4).[2/2016]
(2) Approval may be granted under this section between 1 June 2011 and 31 December 2031 (both dates inclusive) to a company for a period of 5 years; and may be given subject to such conditions as the Minister or authorised body may impose.[37/2014; 2/2016; 41/2020]
[Act 27 of 2021 wef 12/04/2024]
[Act 25 of 2025 wef 19/02/2025]
(2A) The Minister or authorised body must approve for the company one or more shipping‑related support services for the purposes of subsection (1) at the time of granting the approval, and may approve for the company additional shipping‑related support services during the period it is approved.[2/2016]
[Act 41 of 2020 wef 12/04/2024]
(3) A company that is deemed an approved company on 1 June 2011 by virtue of regulations made under subsection (7), is deemed to have been approved for such period not exceeding 10 years from that date as the Minister may specify in the regulations.
(4) The base amount mentioned in subsection (1A) or (5E) is calculated in accordance with the following provisions:(a)
where the approved company had provided one or more of the shipping‑related support services approved for it at any time during the period of 3 years immediately before the date of its approval, the base amount is ascertained by dividing the aggregate net profit before tax as shown in its audited accounts (or such other accounts as the Minister or authorised body may approve for the company) that is derived from providing all of those services during that period by the actual number of months (a period of less than a month being reckoned as one month) during that period in which those services were provided and multiplying by 12;[Act 41 of 2020 wef 12/04/2024]
(b)
where the company had not provided any of the shipping‑related support services approved for it at any time during the period of 3 years immediately before the date of its approval, the base amount is zero; or
(c)
such amount as the Minister may specify in substitution for the amount mentioned in paragraph (a) or (b).[2/2016; 41/2020]
(5) The base amount determined in accordance with subsection (4) applies to the approved company for the entire duration of the period of its approval (but not any extended period of its approval under subsection (5A)), unless the Minister otherwise decides.[2/2016; 41/2020]
(5A) The Minister or authorised body may extend the period of any approval under subsection (2) for further periods of 5 years at any one time, and the extension is subject to the company satisfying such conditions as the Minister or authorised body has imposed on it at the time of granting the extension.[2/2016]
[Act 41 of 2020 wef 12/04/2024]
(5B) The Minister or authorised body must approve for the company one or more shipping‑related support services for the purposes of subsection (5C) or (5CA) at the time of granting the extension, and may approve for the company additional shipping‑related support services during any extended period of its approval.[2/2016; 41/2020]
[Act 41 of 2020 wef 12/04/2024]
(5C) Despite section 43, where an approved company whose period of approval is extended under subsection (5A) did not make an election under subsection (5F) for the extended period, then tax at the rate of A% is levied and must be paid for each year of assessment upon the amount of its income in subsection (5D) that is derived on or after the service approval date and during the extended period, from providing in or from Singapore any shipping‑related support service approved for it under subsection (5B).[41/2020]
(5CA) Despite section 43, where an approved company whose period of approval is extended under subsection (5A) made an election under subsection (5F) for the extended period, then tax at the rate of (0.5 + A)% is levied and must be paid for each year of assessment upon the amount of its income in subsection (5E) that is derived on or after the service approval date and during the extended period, from providing in or from Singapore any shipping‑related support service approved for it under subsection (5B).[41/2020]
(5CB) In subsections (5C) and (5CA), “A” is the concessionary rate of tax applicable to the income of the approved company from providing in or from Singapore any shipping‑related support service approved for it under subsection (2A) or (5B) (as the case may be) immediately before the commencement of the extended period concerned of its approval under subsection (5A).[41/2020]
(5D) In subsection (5C), the amount of the income is that which exceeds the base amount calculated in accordance with subsection (5I).[2/2016]
(5E) In subsection (5CA), the amount of the income is that which exceeds the base amount immediately before the commencement of the extended period concerned of its approval under subsection (5A), which is calculated in accordance with subsection (4) or (5I), as the case may be.[41/2020]
(5F) An approved company whose period of approval is extended under subsection (5A) may make an election for an amount of its income mentioned in subsection (5CA) that is derived on or after the service approval date and during the extended period, from providing in or from Singapore any shipping‑related support service approved for it under subsection (5B), to be taxed in accordance with subsection (5CA).[41/2020]
(5G) An election under subsection (5F) must be made in such form and manner and within such reasonable time as the Minister or authorised body may allow, and must be accompanied by such particulars as the Minister or authorised body determines.[2/2016; 41/2020]
[Act 41 of 2020 wef 12/04/2024]
(5H) An election under subsection (5F) is irrevocable for the extended period of its approval in which the election is made.[41/2020]
(5I) The base amount mentioned in subsection (5D) or (5E) is determined as follows:(a)
where the approved company had provided one or more of the shipping‑related support services approved for it under subsection (5B) at any time during the period of 3 years immediately before the date the extension is granted under subsection (5A), the base amount is ascertained by the formula
where A
is the total net profit before tax as shown in the company’s audited accounts (or such other accounts as the Minister or authorised body may approve for the company) that is derived from providing all of those services during that period of 3 years; and
B
is the actual number of months (a period of less than a month being reckoned as one month) during that period in which those services were provided;
[Act 41 of 2020 wef 12/04/2024]
(b)
where the company had not provided any of the shipping‑related support services approved for it under subsection (5B) at any time during the period mentioned in paragraph (a), the base amount is zero;
(c)
the Minister may in a particular case specify an amount in substitution for the amount mentioned in paragraph (a) or (b).[2/2016; 41/2020]
(5J) The base amount determined in accordance with subsection (5I) applies to the approved company for the entire duration of the extended period concerned of its approval under subsection (5A), unless the Minister otherwise decides.[2/2016; 41/2020]
Application of section to approved SPVs of approved companies
(5K) A company may at the time of making its application or at any time during the period of its approval, apply to the Minister or authorised body for its SPV to be approved in respect of any shipping-related support service provided in or from Singapore by the SPV for the purposes of this section.[Act 25 of 2025 wef 19/02/2025]
(5L) The Minister or authorised body may —(a)
approve an SPV of an approved company between 19 February 2025 and 31 December 2031 (both dates inclusive), subject to such conditions as the Minister or authorised body may impose;
(b)
approve for the SPV one or more shipping-related support services, and may approve for the approved SPV any additional shipping-related support services during the period of its approval; and
(c)
specify the period for which the SPV is approved, which must expire on the date of expiry of the period of approval of the approved company or, if an extension is granted for the approved company under subsection (5A), the expiry of the extension.[Act 25 of 2025 wef 19/02/2025]
(5M) Despite section 43, tax at the rate mentioned in subsection (5N) is to be levied and paid for each year of assessment upon the amount of income in subsection (5O) of an approved SPV derived on or after the service approval date and during the period of its approval under subsection (5L), from providing in or from Singapore any shipping-related support service approved for the SPV under subsection (5L).[Act 25 of 2025 wef 19/02/2025]
(5N) In subsection (5M), the rate of tax is that which is applicable to the income of the approved company derived during the same period under subsection (1), (5C) or (5CA).[Act 25 of 2025 wef 19/02/2025]
(5O) In subsection (5M), the amount of the income is that which exceeds the base amount calculated in accordance with subsection (4) or (5I) (whichever is applicable), subject to the following modifications:(a)
a reference in subsection (4) or (5I) to the approved company is to the approved SPV;
(b)
a reference in subsection (4) or (5I) to shipping-related support services approved for the approved company is to the shipping-related support services approved for the approved SPV;
(c)
a reference in subsection (4) or (5I) to any audited accounts of the approved company or other accounts of the approved company approved by the Minister or authorised body is to the audited accounts of the approved SPV or other accounts of the approved SPV approved by the Minister or authorised body;
(d)
a reference in subsection (4) to the date of approval of the approved company is to the date of approval of the approved SPV;
(e)
a reference in subsection (5I) to the date that the extension is granted under subsection (5A) to an approved company is to the date that the extension is granted to the approved SPV under subsection (5Q).[Act 25 of 2025 wef 19/02/2025]
(5P) Unless the Minister otherwise decides —(a)
the base amount determined in accordance with subsection (4) (as applied by subsection (5O)) applies to the approved SPV for the entire period of its approval; or
(b)
the base amount determined in accordance with subsection (5I) (as applied by subsection (5O)) applies to the approved SPV for any extended period of its approval under subsection (5Q).[Act 25 of 2025 wef 19/02/2025]
(5Q) Where the Minister or authorised body —(a)
has approved an SPV of an approved company; and
(b)
has granted an extension of the period of approval of the approved company under subsection (5A),
the Minister or authorised body may —
(c)
extend the period of approval of the approved SPV by the same period in paragraph (b); and
(d)
approve one or more shipping-related support services for the purposes of subsection (5M) at the time of granting the extension, and may approve any additional shipping-related support services for the approved SPV during the extended period of the SPV’s approval,
but only if the SPV satisfies such conditions as the Minister or authorised body has imposed on it at the time of granting the extension or approval of additional shipping-related support services.
[Act 25 of 2025 wef 19/02/2025]
General provisions
(6) In determining the income of an approved company or approved SPV from the provision of shipping‑related support services approved for it —(a)
the allowances under section 19, 19A, 20, 21, 22 or 23 must be taken into account even if no claim for such allowances has been made; and
(b)
the Comptroller must determine the manner and extent to which —(i)
allowances under section 19, 19A, 20, 21, 22 or 23 and any expenses and donations allowable under this Act are to be deducted; and
(ii)
any loss may be deducted under section 37.[Act 25 of 2025 wef 19/02/2025]
(7) For the purposes of this section, the Minister may make regulations —(a)
to deem a company which, immediately before 1 June 2011, was —(i)
a development and expansion company within the meaning of section 20 of the Economic Expansion Incentives (Relief from Income Tax) Act 1967 engaged in ship management services, ship agency, logistics or freight forwarding, being activities prescribed as qualifying activities within the meaning of that section, and which, in the case of a company engaged in logistics or freight forwarding, is a company —(A)
whose operations are or can be controlled, directly or indirectly, by another company, being one that owns or operates ships;
(B)
which controls or can control, directly or indirectly, the operations of such other company; or
(C)
whose operations are or can be controlled, directly or indirectly, by a person or persons who control or can control, directly or indirectly, the operations of such other company; or
(ii)
an approved company under section 43T,
as an approved company for the purpose of this section from that date;
(b)
to provide for such transitional, supplementary and consequential matters as the Minister may consider necessary or expedient in relation to a company mentioned in paragraph (a), including providing a different base amount for the purposes of subsection (1); and
(c)
generally to give effect to or to carry out the purposes of this section.
(8) In this section —“approved” means approved by the Minister or an authorised body;[Act 41 of 2020 wef 12/04/2024]
“approved company” means a company which —(a)
is incorporated and resident in Singapore;
(b)
carries on the business of providing shipping‑related support services; and
(c)
is approved for the purpose of this section;
“approved related company”, in relation to an approved company, means a related company approved at any time for the approved company for the purpose of the definition of “corporate service”;
“container” has the meaning given by section 43P(7);
“corporate service” means any of the following services provided by an approved company or its approved SPV to an approved related company:(a)
sourcing, procurement and distribution of materials and components, products or services for use in the business of the approved related company (excluding marketing control, planning and brand management);
(b)
training of crew and staff;
(c)
crew management (such as recruitment and selection of qualified and trained seafarers, budgeting and strategic planning in relation to crew requirements, overseeing crew welfare, managing relations with labour unions, handling insurance matters relating to crew, and maintaining personnel data to facilitate searches, planning and analysis);
(d)
business planning, development and co‑ordination (including the performance of economic or investment research and analysis) of information and processes to improve standards of services or products;
(e)
[Deleted by Act 39 of 2017]
(f)
general management and administration (such as risk management, internal audit, budgeting and forecasting, but excluding intellectual property management);
(g)
technical support services (such as marine and offshore engineering technical support, accounting and tax consultancy services and actuary services);
(h)
human resource services;
(i)
financial and treasury services (such as providing credit administration and control, arranging credit facilities, managing funds, and providing guarantees, performance bonds, standby letters of credit and services relating to remittances, arranging interest and currency swaps);
(j)
legal services;
(k)
corporate finance advisory services;
(l)
information technology support services,
and only services provided to an approved related company of that company are treated as “corporate service” in determining if the approved company or approved SPV has provided shipping‑related support service which is corporate service for the purposes of subsections (4) and (5I) (or those provisions as applied by subsection (5O));
[Act 25 of 2025 wef 19/02/2025]
“finance leasing” has the meaning given by section 13P(20) or 43P(7);
“forward freight agreement trading” means the undertaking of a position under a forward freight agreement trade where such trade is in connection with shipping freight rates;
“freight forwarding and logistics service” means managing a customer’s freight, supply chain or logistics process flow;
“maritime technology service” means —(a)
any service relating to the provision or use of maritime drones;
(b)
any service relating to autonomous vessel systems;
(c)
any service relating to maritime cybersecurity; or
(d)
any service relating to any other maritime technology prescribed by rules made under section 7;[Act 25 of 2025 wef 19/02/2025]
“prescribed ship management services” has the meaning given by section 13A(16);
“related company”, in relation to an approved company, means a company that is carrying on a shipping‑related business and —(a)
whose operations are or can be controlled, directly or indirectly, by the approved company;
(b)
which controls or can control, directly or indirectly, the operations of the approved company; or
(c)
whose operations 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 approved company;
“service approval date”, in relation to any shipping‑related support service approved for an approved company under subsection (2A) or (5B) or an approved SPV under subsection (5L) or (5Q), means the date the service is approved for that company or SPV under that subsection or, in the case of corporate service to be provided by the company or SPV to the company’s approved related company, the date the related company is approved as such;[Act 25 of 2025 wef 19/02/2025]
“ship” has the meaning given by section 2(1) of the Merchant Shipping Act 1995;
“ship agency” means the activities performed on behalf of a shipping enterprise in relation to their vessels, masters and crews, cargoes and customers;
“ship broking” means —(a)
the broking of sale and purchase of vessels (including the activity of valuing the vessels);
(b)
the matching of vessel owners (which intend to build new vessels) to shipyards based on the vessel owners’ requirements;
(c)
the matching of vessels to —(i)
cargoes; or
(ii)
vessel owners and vessel charterers;
(d)
the valuation of vessels; or
(e)
the matching of forward freight agreement traders where the forward freight agreement trade is in connection with shipping freight rates,
and includes the services mentioned in subsection (9);
“shipping‑related business” means any of the following:(a)
carriage of passengers, mail, livestock or goods by any ship;
(b)
charter or finance leasing of any ship to any person;
(c)
use of any ship as a dredger, seismic ship or ship used for offshore oil and gas activity;
(d)
use of any ship for towing or salvage operations;
(e)
leasing (including finance leasing) of any container used for the international transportation of goods;
(f)
managing an entity which is in the business of carrying on the charter or leasing (including finance leasing) of containers used for the international transportation of goods, or ships;
(g)
ship broking;
(h)
forward freight agreement trading;
(i)
ship agency;
(j)
prescribed ship management services;
(k)
freight and logistics services in respect of a ship;
(l)
marine insurance;
(m)
offshore and marine engineering (including ship repair and conversion, ship building and offshore engineering);
(n)
maritime law and arbitration;
(o)
shipping finance;
(p)
maritime research and development;
(q)
use of any ship for offshore renewable energy activity, renewable energy activity or offshore mineral activity;[Act 25 of 2025 wef 19/02/2025]
(r)
maritime technology service;[Act 25 of 2025 wef 19/02/2025]
“shipping‑related support service” means any of the following:(a)
ship broking;
(b)
forward freight agreement trading;
(c)
prescribed ship management services;
(d)
ship agency;
(e)
freight forwarding and logistics service;
(f)
corporate service;[Act 25 of 2025 wef 19/02/2025]
(g)
maritime technology service;[Act 25 of 2025 wef 19/02/2025]
“special purpose vehicle” or “SPV”, in relation to an approved company, means a company —(a)
that is incorporated and resident in Singapore;
(b)
at least 50% of the total number of the issued ordinary shares of which are beneficially owned, directly or indirectly, by —(i)
the approved company; or
(ii)
a company which beneficially owns (whether directly or indirectly) at least 50% of the total number of the issued ordinary shares of the approved company; and
(c)
carries on the business of providing shipping-related support services;[2/2016; 34/2016; 39/2017]
[Act 25 of 2025 wef 19/02/2025]
(9) In this section, “ship broking” includes —(a)
for the purpose of subsections (1), (2A), (5B), (5C), (5CA), (5K), (5L), (5M) and (5Q), the provision of research, consultancy or advisory services using information derived from the business of carrying on any of the activities referred to in paragraphs (a) to (e) of the definition of “ship broking” in subsection (8), where the total sum of the fees derived by the approved company or approved SPV (as the case may be) from the research, consultancy and advisory services in the basis period for the year of assessment concerned (called in this paragraph the said sum) is not more than 20% of the sum of —(i)
the total fees and commissions derived by the approved company or approved SPV (as the case may be) from all of those other activities in the basis period for that year of assessment; and[Act 25 of 2025 wef 19/02/2025]
(ii)
the said sum,
or where the Minister otherwise allows such services to be considered “ship broking”; and
[Act 25 of 2025 wef 19/02/2025]
(b)
for the purpose of subsections (4) and (5I) (or those provisions as applied by subsection (5O)), the provision, within any financial year or part thereof of the approved company or approved SPV (as the case may be) that falls within the period of 3 years immediately before the date of its approval, of research, consultancy or advisory services using information derived from the business of carrying on any of the activities referred to in paragraphs (a) to (e) of the definition of “ship broking” in subsection (8), where the total sum of the fees derived by the approved company or approved SPV (as the case may be) from the research, consultancy and advisory services in that financial year or part thereof (called in this paragraph the said sum) is not more than 20% of the sum of —(i)
the total fees and commissions derived by the approved company or approved SPV (as the case may be) from all of those other activities in that financial year or part thereof; and[Act 25 of 2025 wef 19/02/2025]
(ii)
the said sum,
or where the Minister otherwise allows such services to be considered “ship broking”.
[2/2016; 41/2020]
[Act 25 of 2025 wef 19/02/2025]
(10) For the purposes of the definition of “related company” in subsection (8), a company (called in this subsection the first company) is deemed to be a related company of another company if —(a)
at least 25% of the total number of its issued shares are beneficially owned, directly or indirectly, by the other company;
(b)
at least 25% of the total number of the issued shares of the other company are beneficially owned, directly or indirectly, by the first company; or
(c)
at least 25% of the total number of issued shares in each of the 2 companies are beneficially owned, directly or indirectly, by a third company.[43ZF
—(1) Despite section 43, tax at the rate of 10% is to be levied and paid for each year of assessment upon the amount of income in subsection (1A) of an approved company derived on or after the service approval date and during the period of its approval under subsection (2) (but not any extended period of its approval under subsection (5A)), from providing in or from Singapore any shipping‑related support service approved for it under subsection (2A).[2/2016]
(1A) In subsection (1), the amount of the income is that which exceeds the base amount calculated in accordance with subsection (4).[2/2016]
(2) Approval may be granted under this section between 1 June 2011 and 31 December 2031 (both dates inclusive) to a company for a period of 5 years; and may be given subject to such conditions as the Minister or authorised body may impose.[37/2014; 2/2016; 41/2020]
[Act 27 of 2021 wef 12/04/2024]
[Act 25 of 2025 wef 19/02/2025]
(2A) The Minister or authorised body must approve for the company one or more shipping‑related support services for the purposes of subsection (1) at the time of granting the approval, and may approve for the company additional shipping‑related support services during the period it is approved.[2/2016]
[Act 41 of 2020 wef 12/04/2024]
(3) A company that is deemed an approved company on 1 June 2011 by virtue of regulations made under subsection (7), is deemed to have been approved for such period not exceeding 10 years from that date as the Minister may specify in the regulations.
(4) The base amount mentioned in subsection (1A) or (5E) is calculated in accordance with the following provisions:(a)
where the approved company had provided one or more of the shipping‑related support services approved for it at any time during the period of 3 years immediately before the date of its approval, the base amount is ascertained by dividing the aggregate net profit before tax as shown in its audited accounts (or such other accounts as the Minister or authorised body may approve for the company) that is derived from providing all of those services during that period by the actual number of months (a period of less than a month being reckoned as one month) during that period in which those services were provided and multiplying by 12;[Act 41 of 2020 wef 12/04/2024]
(b)
where the company had not provided any of the shipping‑related support services approved for it at any time during the period of 3 years immediately before the date of its approval, the base amount is zero; or
(c)
such amount as the Minister may specify in substitution for the amount mentioned in paragraph (a) or (b).[2/2016; 41/2020]
(5) The base amount determined in accordance with subsection (4) applies to the approved company for the entire duration of the period of its approval (but not any extended period of its approval under subsection (5A)), unless the Minister otherwise decides.[2/2016; 41/2020]
(5A) The Minister or authorised body may extend the period of any approval under subsection (2) for further periods of 5 years at any one time, and the extension is subject to the company satisfying such conditions as the Minister or authorised body has imposed on it at the time of granting the extension.[2/2016]
[Act 41 of 2020 wef 12/04/2024]
(5B) The Minister or authorised body must approve for the company one or more shipping‑related support services for the purposes of subsection (5C) or (5CA) at the time of granting the extension, and may approve for the company additional shipping‑related support services during any extended period of its approval.[2/2016; 41/2020]
[Act 41 of 2020 wef 12/04/2024]
(5C) Despite section 43, where an approved company whose period of approval is extended under subsection (5A) did not make an election under subsection (5F) for the extended period, then tax at the rate of A% is levied and must be paid for each year of assessment upon the amount of its income in subsection (5D) that is derived on or after the service approval date and during the extended period, from providing in or from Singapore any shipping‑related support service approved for it under subsection (5B).[41/2020]
(5CA) Despite section 43, where an approved company whose period of approval is extended under subsection (5A) made an election under subsection (5F) for the extended period, then tax at the rate of (0.5 + A)% is levied and must be paid for each year of assessment upon the amount of its income in subsection (5E) that is derived on or after the service approval date and during the extended period, from providing in or from Singapore any shipping‑related support service approved for it under subsection (5B).[41/2020]
(5CB) In subsections (5C) and (5CA), “A” is the concessionary rate of tax applicable to the income of the approved company from providing in or from Singapore any shipping‑related support service approved for it under subsection (2A) or (5B) (as the case may be) immediately before the commencement of the extended period concerned of its approval under subsection (5A).[41/2020]
(5D) In subsection (5C), the amount of the income is that which exceeds the base amount calculated in accordance with subsection (5I).[2/2016]
(5E) In subsection (5CA), the amount of the income is that which exceeds the base amount immediately before the commencement of the extended period concerned of its approval under subsection (5A), which is calculated in accordance with subsection (4) or (5I), as the case may be.[41/2020]
(5F) An approved company whose period of approval is extended under subsection (5A) may make an election for an amount of its income mentioned in subsection (5CA) that is derived on or after the service approval date and during the extended period, from providing in or from Singapore any shipping‑related support service approved for it under subsection (5B), to be taxed in accordance with subsection (5CA).[41/2020]
(5G) An election under subsection (5F) must be made in such form and manner and within such reasonable time as the Minister or authorised body may allow, and must be accompanied by such particulars as the Minister or authorised body determines.[2/2016; 41/2020]
[Act 41 of 2020 wef 12/04/2024]
(5H) An election under subsection (5F) is irrevocable for the extended period of its approval in which the election is made.[41/2020]
(5I) The base amount mentioned in subsection (5D) or (5E) is determined as follows:(a)
where the approved company had provided one or more of the shipping‑related support services approved for it under subsection (5B) at any time during the period of 3 years immediately before the date the extension is granted under subsection (5A), the base amount is ascertained by the formula
where A
is the total net profit before tax as shown in the company’s audited accounts (or such other accounts as the Minister or authorised body may approve for the company) that is derived from providing all of those services during that period of 3 years; and
B
is the actual number of months (a period of less than a month being reckoned as one month) during that period in which those services were provided;
[Act 41 of 2020 wef 12/04/2024]
(b)
where the company had not provided any of the shipping‑related support services approved for it under subsection (5B) at any time during the period mentioned in paragraph (a), the base amount is zero;
(c)
the Minister may in a particular case specify an amount in substitution for the amount mentioned in paragraph (a) or (b).[2/2016; 41/2020]
(5J) The base amount determined in accordance with subsection (5I) applies to the approved company for the entire duration of the extended period concerned of its approval under subsection (5A), unless the Minister otherwise decides.[2/2016; 41/2020]
(5K) A company may at the time of making its application or at any time during the period of its approval, apply to the Minister or authorised body for its SPV to be approved in respect of any shipping-related support service provided in or from Singapore by the SPV for the purposes of this section.[Act 25 of 2025 wef 19/02/2025]
(5L) The Minister or authorised body may —(a)
approve an SPV of an approved company between 19 February 2025 and 31 December 2031 (both dates inclusive), subject to such conditions as the Minister or authorised body may impose;
(b)
approve for the SPV one or more shipping-related support services, and may approve for the approved SPV any additional shipping-related support services during the period of its approval; and
(c)
specify the period for which the SPV is approved, which must expire on the date of expiry of the period of approval of the approved company or, if an extension is granted for the approved company under subsection (5A), the expiry of the extension.[Act 25 of 2025 wef 19/02/2025]
(5M) Despite section 43, tax at the rate mentioned in subsection (5N) is to be levied and paid for each year of assessment upon the amount of income in subsection (5O) of an approved SPV derived on or after the service approval date and during the period of its approval under subsection (5L), from providing in or from Singapore any shipping-related support service approved for the SPV under subsection (5L).[Act 25 of 2025 wef 19/02/2025]
(5N) In subsection (5M), the rate of tax is that which is applicable to the income of the approved company derived during the same period under subsection (1), (5C) or (5CA).[Act 25 of 2025 wef 19/02/2025]
(5O) In subsection (5M), the amount of the income is that which exceeds the base amount calculated in accordance with subsection (4) or (5I) (whichever is applicable), subject to the following modifications:(a)
a reference in subsection (4) or (5I) to the approved company is to the approved SPV;
(b)
a reference in subsection (4) or (5I) to shipping-related support services approved for the approved company is to the shipping-related support services approved for the approved SPV;
(c)
a reference in subsection (4) or (5I) to any audited accounts of the approved company or other accounts of the approved company approved by the Minister or authorised body is to the audited accounts of the approved SPV or other accounts of the approved SPV approved by the Minister or authorised body;
(d)
a reference in subsection (4) to the date of approval of the approved company is to the date of approval of the approved SPV;
(e)
a reference in subsection (5I) to the date that the extension is granted under subsection (5A) to an approved company is to the date that the extension is granted to the approved SPV under subsection (5Q).[Act 25 of 2025 wef 19/02/2025]
(5P) Unless the Minister otherwise decides —(a)
the base amount determined in accordance with subsection (4) (as applied by subsection (5O)) applies to the approved SPV for the entire period of its approval; or
(b)
the base amount determined in accordance with subsection (5I) (as applied by subsection (5O)) applies to the approved SPV for any extended period of its approval under subsection (5Q).[Act 25 of 2025 wef 19/02/2025]
(5Q) Where the Minister or authorised body —(a)
has approved an SPV of an approved company; and
(b)
has granted an extension of the period of approval of the approved company under subsection (5A),
the Minister or authorised body may —
(c)
extend the period of approval of the approved SPV by the same period in paragraph (b); and
(d)
approve one or more shipping-related support services for the purposes of subsection (5M) at the time of granting the extension, and may approve any additional shipping-related support services for the approved SPV during the extended period of the SPV’s approval,
but only if the SPV satisfies such conditions as the Minister or authorised body has imposed on it at the time of granting the extension or approval of additional shipping-related support services.
[Act 25 of 2025 wef 19/02/2025]
(6) In determining the income of an approved company or approved SPV from the provision of shipping‑related support services approved for it —(a)
the allowances under section 19, 19A, 20, 21, 22 or 23 must be taken into account even if no claim for such allowances has been made; and
(b)
the Comptroller must determine the manner and extent to which —(i)
allowances under section 19, 19A, 20, 21, 22 or 23 and any expenses and donations allowable under this Act are to be deducted; and
(ii)
any loss may be deducted under section 37.[Act 25 of 2025 wef 19/02/2025]
(7) For the purposes of this section, the Minister may make regulations —(a)
to deem a company which, immediately before 1 June 2011, was —(i)
a development and expansion company within the meaning of section 20 of the Economic Expansion Incentives (Relief from Income Tax) Act 1967 engaged in ship management services, ship agency, logistics or freight forwarding, being activities prescribed as qualifying activities within the meaning of that section, and which, in the case of a company engaged in logistics or freight forwarding, is a company —(A)
whose operations are or can be controlled, directly or indirectly, by another company, being one that owns or operates ships;
(B)
which controls or can control, directly or indirectly, the operations of such other company; or
(C)
whose operations are or can be controlled, directly or indirectly, by a person or persons who control or can control, directly or indirectly, the operations of such other company; or
(ii)
an approved company under section 43T,
as an approved company for the purpose of this section from that date;
(b)
to provide for such transitional, supplementary and consequential matters as the Minister may consider necessary or expedient in relation to a company mentioned in paragraph (a), including providing a different base amount for the purposes of subsection (1); and
(c)
generally to give effect to or to carry out the purposes of this section.
(8) In this section —“approved” means approved by the Minister or an authorised body;[Act 41 of 2020 wef 12/04/2024]
“approved company” means a company which —(a)
is incorporated and resident in Singapore;
(b)
carries on the business of providing shipping‑related support services; and
(c)
is approved for the purpose of this section;
“approved related company”, in relation to an approved company, means a related company approved at any time for the approved company for the purpose of the definition of “corporate service”;
“container” has the meaning given by section 43P(7);
“corporate service” means any of the following services provided by an approved company or its approved SPV to an approved related company:(a)
sourcing, procurement and distribution of materials and components, products or services for use in the business of the approved related company (excluding marketing control, planning and brand management);
(b)
training of crew and staff;
(c)
crew management (such as recruitment and selection of qualified and trained seafarers, budgeting and strategic planning in relation to crew requirements, overseeing crew welfare, managing relations with labour unions, handling insurance matters relating to crew, and maintaining personnel data to facilitate searches, planning and analysis);
(d)
business planning, development and co‑ordination (including the performance of economic or investment research and analysis) of information and processes to improve standards of services or products;
(e)
[Deleted by Act 39 of 2017]
(f)
general management and administration (such as risk management, internal audit, budgeting and forecasting, but excluding intellectual property management);
(g)
technical support services (such as marine and offshore engineering technical support, accounting and tax consultancy services and actuary services);
(h)
human resource services;
(i)
financial and treasury services (such as providing credit administration and control, arranging credit facilities, managing funds, and providing guarantees, performance bonds, standby letters of credit and services relating to remittances, arranging interest and currency swaps);
(j)
legal services;
(k)
corporate finance advisory services;
(l)
information technology support services,
and only services provided to an approved related company of that company are treated as “corporate service” in determining if the approved company or approved SPV has provided shipping‑related support service which is corporate service for the purposes of subsections (4) and (5I) (or those provisions as applied by subsection (5O));
[Act 25 of 2025 wef 19/02/2025]
“finance leasing” has the meaning given by section 13P(20) or 43P(7);
“forward freight agreement trading” means the undertaking of a position under a forward freight agreement trade where such trade is in connection with shipping freight rates;
“freight forwarding and logistics service” means managing a customer’s freight, supply chain or logistics process flow;
“maritime technology service” means —(a)
any service relating to the provision or use of maritime drones;
(b)
any service relating to autonomous vessel systems;
(c)
any service relating to maritime cybersecurity; or
(d)
any service relating to any other maritime technology prescribed by rules made under section 7;[Act 25 of 2025 wef 19/02/2025]
“prescribed ship management services” has the meaning given by section 13A(16);
“related company”, in relation to an approved company, means a company that is carrying on a shipping‑related business and —(a)
whose operations are or can be controlled, directly or indirectly, by the approved company;
(b)
which controls or can control, directly or indirectly, the operations of the approved company; or
(c)
whose operations 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 approved company;
“service approval date”, in relation to any shipping‑related support service approved for an approved company under subsection (2A) or (5B) or an approved SPV under subsection (5L) or (5Q), means the date the service is approved for that company or SPV under that subsection or, in the case of corporate service to be provided by the company or SPV to the company’s approved related company, the date the related company is approved as such;[Act 25 of 2025 wef 19/02/2025]
“ship” has the meaning given by section 2(1) of the Merchant Shipping Act 1995;
“ship agency” means the activities performed on behalf of a shipping enterprise in relation to their vessels, masters and crews, cargoes and customers;
“ship broking” means —(a)
the broking of sale and purchase of vessels (including the activity of valuing the vessels);
(b)
the matching of vessel owners (which intend to build new vessels) to shipyards based on the vessel owners’ requirements;
(c)
the matching of vessels to —(i)
cargoes; or
(ii)
vessel owners and vessel charterers;
(d)
the valuation of vessels; or
(e)
the matching of forward freight agreement traders where the forward freight agreement trade is in connection with shipping freight rates,
and includes the services mentioned in subsection (9);
“shipping‑related business” means any of the following:(a)
carriage of passengers, mail, livestock or goods by any ship;
(b)
charter or finance leasing of any ship to any person;
(c)
use of any ship as a dredger, seismic ship or ship used for offshore oil and gas activity;
(d)
use of any ship for towing or salvage operations;
(e)
leasing (including finance leasing) of any container used for the international transportation of goods;
(f)
managing an entity which is in the business of carrying on the charter or leasing (including finance leasing) of containers used for the international transportation of goods, or ships;
(g)
ship broking;
(h)
forward freight agreement trading;
(i)
ship agency;
(j)
prescribed ship management services;
(k)
freight and logistics services in respect of a ship;
(l)
marine insurance;
(m)
offshore and marine engineering (including ship repair and conversion, ship building and offshore engineering);
(n)
maritime law and arbitration;
(o)
shipping finance;
(p)
maritime research and development;
(q)
use of any ship for offshore renewable energy activity, renewable energy activity or offshore mineral activity;[Act 25 of 2025 wef 19/02/2025]
(r)
maritime technology service;[Act 25 of 2025 wef 19/02/2025]
“shipping‑related support service” means any of the following:(a)
ship broking;
(b)
forward freight agreement trading;
(c)
prescribed ship management services;
(d)
ship agency;
(e)
freight forwarding and logistics service;
(f)
corporate service;[Act 25 of 2025 wef 19/02/2025]
(g)
maritime technology service;[Act 25 of 2025 wef 19/02/2025]
“special purpose vehicle” or “SPV”, in relation to an approved company, means a company —(a)
that is incorporated and resident in Singapore;
(b)
at least 50% of the total number of the issued ordinary shares of which are beneficially owned, directly or indirectly, by —(i)
the approved company; or
(ii)
a company which beneficially owns (whether directly or indirectly) at least 50% of the total number of the issued ordinary shares of the approved company; and
(c)
carries on the business of providing shipping-related support services;[2/2016; 34/2016; 39/2017]
[Act 25 of 2025 wef 19/02/2025]
(9) In this section, “ship broking” includes —(a)
for the purpose of subsections (1), (2A), (5B), (5C), (5CA), (5K), (5L), (5M) and (5Q), the provision of research, consultancy or advisory services using information derived from the business of carrying on any of the activities referred to in paragraphs (a) to (e) of the definition of “ship broking” in subsection (8), where the total sum of the fees derived by the approved company or approved SPV (as the case may be) from the research, consultancy and advisory services in the basis period for the year of assessment concerned (called in this paragraph the said sum) is not more than 20% of the sum of —(i)
the total fees and commissions derived by the approved company or approved SPV (as the case may be) from all of those other activities in the basis period for that year of assessment; and[Act 25 of 2025 wef 19/02/2025]
(ii)
the said sum,
or where the Minister otherwise allows such services to be considered “ship broking”; and
[Act 25 of 2025 wef 19/02/2025]
(b)
for the purpose of subsections (4) and (5I) (or those provisions as applied by subsection (5O)), the provision, within any financial year or part thereof of the approved company or approved SPV (as the case may be) that falls within the period of 3 years immediately before the date of its approval, of research, consultancy or advisory services using information derived from the business of carrying on any of the activities referred to in paragraphs (a) to (e) of the definition of “ship broking” in subsection (8), where the total sum of the fees derived by the approved company or approved SPV (as the case may be) from the research, consultancy and advisory services in that financial year or part thereof (called in this paragraph the said sum) is not more than 20% of the sum of —(i)
the total fees and commissions derived by the approved company or approved SPV (as the case may be) from all of those other activities in that financial year or part thereof; and[Act 25 of 2025 wef 19/02/2025]
(ii)
the said sum,
or where the Minister otherwise allows such services to be considered “ship broking”.
[2/2016; 41/2020]
[Act 25 of 2025 wef 19/02/2025]
(10) For the purposes of the definition of “related company” in subsection (8), a company (called in this subsection the first company) is deemed to be a related company of another company if —(a)
at least 25% of the total number of its issued shares are beneficially owned, directly or indirectly, by the other company;
(b)
at least 25% of the total number of the issued shares of the other company are beneficially owned, directly or indirectly, by the first company; or
(c)
at least 25% of the total number of issued shares in each of the 2 companies are beneficially owned, directly or indirectly, by a third company.[43ZF
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