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Exemption of certain income of prescribed sovereign fund entity and approved foreign government‑owned entity

Income Tax Act 1947

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—(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; and(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.(2) The Minister or such person as he may appoint may, at any time between 1 April 2010 and 31 December 2024 (both dates inclusive), approve a foreign government‑owned entity for the purpose of subsection (1).(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;(aa)provide for renewal of an approval;(b)provide for the determination of the amount of income of a prescribed sovereign fund entity or an approved foreign government‑owned entity that is exempt from tax;(c)provide for the deduction of expenses, allowances and losses of a prescribed sovereign fund entity or an approved foreign government‑owned entity otherwise than in accordance with this Act; and(d)make provision generally for giving full effect to or for carrying out the purposes of this section.(4) In this section —“foreign government‑owned entity” means —(a)an entity wholly and beneficially owned (whether directly or indirectly) by the government or other public authority of a foreign country;(b)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;(c)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(d)an entity that is incorporated, formed or established by an entity mentioned in paragraph (c) 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;“prescribed sovereign fund entity” means a sovereign fund entity that satisfies such conditions as may be prescribed;“sovereign fund entity” means —(a)the government or other public authority of a foreign country;(b)an entity wholly and beneficially owned by the government or other public authority of a foreign country;(c)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;(d)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(e)an entity that is incorporated, formed or established by an entity mentioned in paragraph (d) 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.[13Y

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