Finance (Income Taxes) Bill

—(1) This Act is the Finance (Income Taxes) Act 2025.(2) Section 5(1)(a) is deemed to have come into operation on 1 January 2013.(3) Section 52 is deemed to have come into operation on 1 January 2024.(4) Sections 9 and 32(h) are deemed to have come into operation on 7 February 2024.(5) Sections 5(1)(f), 32(g), 33, 34(1) and 38 are deemed to have come into operation on 1 January 2025.(6) Sections 27(e) and (f) and 42 are deemed to have come into operation on 1 February 2025.(7) Sections 2, 6(a), (b), (d) and (e), 7(1), 8, 13, 18, 20(1)(g) and (j), 22, 29, 34(2), 35, 36, 37, 39, 49(a) and 51 are deemed to have come into operation on 19 February 2025.(8) Section 32(a), (b), (c), (e), (i) and (j) is deemed to have come into operation on 1 July 2025.(9) Sections 25, 26 and 54 come into operation on a date that the Minister appoints by notification in the Gazette.(10) The provisions of Part 2 —(a)are deemed to have come into operation on the same date as that of the provisions of the Multinational Enterprise (Minimum Tax) Act 2024 (except sections 85 and 86), as specified in the Multinational Enterprise (Minimum Tax) Act 2024 (Declaration under Section 1(3)) Order 2024 (G.N. No. S 1060/2024); and(b)have effect in relation to an MNE group starting from the first financial year of that MNE group as specified in that Order.(11) To avoid doubt, section 1(5) and (6) of that Act (order declaring that an Act provision ceases to be in force) applies to a provision of that Act that is amended or inserted by a provision of Part 2 of this Act.

This Act is the Finance (Income Taxes) Act 2025.

Section 5(1)(a) is deemed to have come into operation on 1 January 2013.

Section 52 is deemed to have come into operation on 1 January 2024.

Sections 9 and 32(h) are deemed to have come into operation on 7 February 2024.

Sections 5(1)(f), 32(g), 33, 34(1) and 38 are deemed to have come into operation on 1 January 2025.

Sections 27(e) and (f) and 42 are deemed to have come into operation on 1 February 2025.

Sections 2, 6(a), (b), (d) and (e), 7(1), 8, 13, 18, 20(1)(g) and (j), 22, 29, 34(2), 35, 36, 37, 39, 49(a) and 51 are deemed to have come into operation on 19 February 2025.

Section 32(a), (b), (c), (e), (i) and (j) is deemed to have come into operation on 1 July 2025.

Sections 25, 26 and 54 come into operation on a date that the Minister appoints by notification in the Gazette.

The provisions of Part 2 —(a)are deemed to have come into operation on the same date as that of the provisions of the Multinational Enterprise (Minimum Tax) Act 2024 (except sections 85 and 86), as specified in the Multinational Enterprise (Minimum Tax) Act 2024 (Declaration under Section 1(3)) Order 2024 (G.N. No. S 1060/2024); and(b)have effect in relation to an MNE group starting from the first financial year of that MNE group as specified in that Order.

To avoid doubt, section 1(5) and (6) of that Act (order declaring that an Act provision ceases to be in force) applies to a provision of that Act that is amended or inserted by a provision of Part 2 of this Act.

AMENDMENT OF INCOME TAX ACT 1947

In the Income Tax Act 1947 (called in this Part the ITA), in section 2 —(a)in subsection (1), after the definition of “related party”, insert —“ “renewable energy” means —(a)thermal power;(b)geothermal power;(c)solar power;(d)wind power;(e)osmotic power;(f)tidal power;(g)wave power; or(h)hydropower;”; and(b)after subsection (3A), insert —“(3B) In this Act, a ship (as defined in section 2(1) of the Merchant Shipping Act 1995) is used for renewable energy activity if it is used for the subsea distribution, exploration or exploitation of renewable energy, or to support any activity that is ancillary to the distribution, exploration or exploitation.”.

“(3B) In this Act, a ship (as defined in section 2(1) of the Merchant Shipping Act 1995) is used for renewable energy activity if it is used for the subsea distribution, exploration or exploitation of renewable energy, or to support any activity that is ancillary to the distribution, exploration or exploitation.”.

In the ITA, in section 2A(4), replace “93A” with “92L, 93, 93AA, 93A, 93C”.

In the ITA, in section 10, after subsection (7), insert —“(7AA) Despite subsection (7), if —(a)within 5 years after the year in which the later of the dates mentioned in subsection (7)(c) falls, either the individual (X) exercises, assigns, releases or acquires the right or benefit or, if the right or benefit is subject to any restriction on the sale of the shares so acquired, the restriction ceases to apply;(b)any gains or profits of X computed in accordance with subsection (6) would have been lower than the amount computed in accordance with subsection (7); and(c)X makes an application under subsection (7AC),then X’s gains or profits from the right or benefit are computed in accordance with subsection (6)(a) to (d) (whichever is applicable) and treated as income derived on the later of the dates mentioned in subsection (7)(c), and is chargeable to tax under subsection (1)(b).(7AB) Subsection (7) does not apply if —(a)within 5 years after the year in which the later of the dates mentioned in subsection (7)(c) falls, the right or benefit of the individual (also called X) to acquire the shares lapses, or is forfeited or cancelled; and (b)X makes an application under subsection (7AC).(7AC) In a case mentioned in subsection (7AA)(a) and (b) or subsection (7AB)(a), X may, within 5 years after the year in which the later of the dates mentioned in subsection (7)(c) falls, apply to the Comptroller to revise any assessment made on X in respect of the gains or profits deemed to be income under subsection (7).”.

“(7AA) Despite subsection (7), if —(a)within 5 years after the year in which the later of the dates mentioned in subsection (7)(c) falls, either the individual (X) exercises, assigns, releases or acquires the right or benefit or, if the right or benefit is subject to any restriction on the sale of the shares so acquired, the restriction ceases to apply;(b)any gains or profits of X computed in accordance with subsection (6) would have been lower than the amount computed in accordance with subsection (7); and(c)X makes an application under subsection (7AC),then X’s gains or profits from the right or benefit are computed in accordance with subsection (6)(a) to (d) (whichever is applicable) and treated as income derived on the later of the dates mentioned in subsection (7)(c), and is chargeable to tax under subsection (1)(b).

Subsection (7) does not apply if —(a)within 5 years after the year in which the later of the dates mentioned in subsection (7)(c) falls, the right or benefit of the individual (also called X) to acquire the shares lapses, or is forfeited or cancelled; and (b)X makes an application under subsection (7AC).

In a case mentioned in subsection (7AA)(a) and (b) or subsection (7AB)(a), X may, within 5 years after the year in which the later of the dates mentioned in subsection (7)(c) falls, apply to the Comptroller to revise any assessment made on X in respect of the gains or profits deemed to be income under subsection (7).”.

—(1) In the ITA, in section 13 —(a)in subsection (1), after paragraph (zp), insert —“(zpa)any payment known as the Workfare Training Support Training Allowance received under the public scheme known as the Workfare Training Support scheme (or any name that replaces that name), or any payment received under any public scheme that succeeds or replaces that scheme, for attending a course that is specified on, or specified on an Internet website that is accessible from, a prescribed Internet website on the date of commencement of the course, as a course that is eligible for the payment;”;(b)in subsection (1)(zt)(iv), delete “and” at the end;(c)in subsection (1)(zu), replace the full‑stop at the end with a semi‑colon;(d)in subsection (1), after paragraph (zu), insert —“(zv)any payment known as the SkillsFuture Mid‑Career Training Allowance received under the public scheme known as the SkillsFuture Level‑Up Programme, for attending a course that is specified on, or specified on an Internet website that is accessible from, a prescribed Internet website on the date of commencement of the course or 10 March 2025 (whichever is the later), as a course that is eligible for the payment;(zw)any payment known as the Workfare Skills Support (Level‑Up) Full Time Training Allowance received under the public scheme known as the Workfare Skills Support (Level‑Up) scheme, for attending a course that is specified on, or specified on an Internet website that is accessible from, a prescribed Internet website on the date of commencement of the course, as a course that is eligible for the payment;(zx)any amount payable from the public scheme known as the Workforce Singapore’s SkillsFuture Jobseeker Support scheme, that is part of the Budget Statement of the Government dated 18 February 2025; and(zy)any contribution to the Central Provident Fund in respect of an individual made by the Government under the Earn and Save Bonus (ESB) that is part of the public scheme known as the Majulah Package.”;(e)after subsection (2J), insert —“(2K) Rules made under section 7(1) to prescribe the Internet website mentioned in subsection (1)(zpa) may be made to take effect from (and including) 1 January 2013.(2L) Rules made under section 7(1) to prescribe the Internet website mentioned in subsection (1)(zv) may be made to take effect from (and including) 10 March 2025.”;(f)after subsection (4), insert —“(5) A notification made under subsection (4) may exempt from tax any payment in the nature of any income referred to in section 12(6) or (7) that is made —(a)by a shipping financing arrangement enterprise that is approved by the Minister or an authorised body for the purposes of this subsection; and(b)to a person that is not resident in Singapore and either —(i)does not (alone or in association with others) carry on a business in Singapore and does not have a permanent establishment in Singapore; or (ii)carries on a business in Singapore (alone or in association with others) or has a permanent establishment in Singapore, but —(A)the arrangement, management or service relating to the loan or indebtedness concerned as described in section 12(6)(a); or(B)the act for which the royalty or other payment as described in section 12(7) is made,is not performed through that business or permanent establishment, or the giving of the guarantee relating to the loan or indebtedness concerned as described in section 12(6)(a) is not effectively connected with that business or permanent establishment.(5A) An approval of a shipping financing arrangement enterprise for the purposes of subsection (5) may be granted between 1 January 2025 and 31 December 2031 (both dates inclusive), and is —(a)subject to any condition specified by the Minister or authorised body; and(b)for a period not exceeding 5 years specified by the Minister or authorised body, except that the Minister or authorised body may extend the period for any further periods that the Minister or authorised body thinks fit.(5B) A notification made under subsection (4) for the purposes of subsection (5) may be made to take effect from (and including) 1 January 2025.(5C) For the purposes of subsections (5), (5A) and this subsection —“approved special purpose vehicle”, in relation to a shipping financing arrangement enterprise, means a company, a partnership or a registered business trust that undertakes or intends to undertake any activity mentioned in paragraph (a) or (b) of the definition of “shipping financing arrangement enterprise” involving ships or containers controlled and managed by the enterprise, and is approved by the Minister or authorised body to be an approved special purpose vehicle of the enterprise;“finance leasing” has the meaning given by section 13A(16);“shipping financing arrangement enterprise” means —(a)a company resident in Singapore that owns or operates a ship, or intends to own or operate a ship, either directly or using an approved special purpose vehicle; or(b)a company incorporated and resident in Singapore, a partnership registered under any written law in Singapore or a registered business trust that undertakes or intends to undertake, either directly or using an approved special purpose vehicle, the chartering or leasing (including by finance leasing) of a ship, or a container as defined under section 43P(7).”;(g)in subsections (12A), (12B)(a) and (12C), replace “2026” with “2031”;(h)in subsection (12A)(c), delete “incorporated in Singapore”; and(i)after subsection (13A), insert —“(14) Any order made under subsection (12) in relation to the following income may be made to take effect on 19 February 2025:(a)any income received in Singapore by a company resident in Singapore, the share capital of which is 100% owned (whether directly or indirectly) by the trustee of a real estate investment trust;(b)any rental income or property‑related income (within the meaning of that order) or income ancillary to any such income, received in Singapore by —(i)the trustee of a real estate investment trust who is resident in Singapore; or (ii)the trustee of a sub‑trust of a real estate investment trust who is resident in Singapore, where all rights or interests in the property of the sub‑trust are held for the benefit of the beneficiaries of the real estate investment trust,where the income is derived from the direct holding of immovable property situated outside Singapore by the trustee in sub‑paragraph (i) or (ii), as the case may be.(14A) Any order made under subsection (12) in relation to income received by a person resident in Singapore, connected with any loan taken or debt securities issued for the purpose of acquiring, developing, investing in, owning or operating an offshore infrastructure asset or project, may be made to take effect from (and including) 1 January 2026.”.(2) Section 13(1)(zv), (zx) and (zy) of the ITA applies for the year of assessment 2026 and any subsequent year of assessment.(3) Section 13(1)(zw) of the ITA applies for the year of assessment 2027 and any subsequent year of assessment.

In the ITA, in section 13 —(a)in subsection (1), after paragraph (zp), insert —“(zpa)any payment known as the Workfare Training Support Training Allowance received under the public scheme known as the Workfare Training Support scheme (or any name that replaces that name), or any payment received under any public scheme that succeeds or replaces that scheme, for attending a course that is specified on, or specified on an Internet website that is accessible from, a prescribed Internet website on the date of commencement of the course, as a course that is eligible for the payment;”;(b)in subsection (1)(zt)(iv), delete “and” at the end;(c)in subsection (1)(zu), replace the full‑stop at the end with a semi‑colon;(d)in subsection (1), after paragraph (zu), insert —“(zv)any payment known as the SkillsFuture Mid‑Career Training Allowance received under the public scheme known as the SkillsFuture Level‑Up Programme, for attending a course that is specified on, or specified on an Internet website that is accessible from, a prescribed Internet website on the date of commencement of the course or 10 March 2025 (whichever is the later), as a course that is eligible for the payment;(zw)any payment known as the Workfare Skills Support (Level‑Up) Full Time Training Allowance received under the public scheme known as the Workfare Skills Support (Level‑Up) scheme, for attending a course that is specified on, or specified on an Internet website that is accessible from, a prescribed Internet website on the date of commencement of the course, as a course that is eligible for the payment;(zx)any amount payable from the public scheme known as the Workforce Singapore’s SkillsFuture Jobseeker Support scheme, that is part of the Budget Statement of the Government dated 18 February 2025; and(zy)any contribution to the Central Provident Fund in respect of an individual made by the Government under the Earn and Save Bonus (ESB) that is part of the public scheme known as the Majulah Package.”;(e)after subsection (2J), insert —“(2K) Rules made under section 7(1) to prescribe the Internet website mentioned in subsection (1)(zpa) may be made to take effect from (and including) 1 January 2013.(2L) Rules made under section 7(1) to prescribe the Internet website mentioned in subsection (1)(zv) may be made to take effect from (and including) 10 March 2025.”;(f)after subsection (4), insert —“(5) A notification made under subsection (4) may exempt from tax any payment in the nature of any income referred to in section 12(6) or (7) that is made —(a)by a shipping financing arrangement enterprise that is approved by the Minister or an authorised body for the purposes of this subsection; and(b)to a person that is not resident in Singapore and either —(i)does not (alone or in association with others) carry on a business in Singapore and does not have a permanent establishment in Singapore; or (ii)carries on a business in Singapore (alone or in association with others) or has a permanent establishment in Singapore, but —(A)the arrangement, management or service relating to the loan or indebtedness concerned as described in section 12(6)(a); or(B)the act for which the royalty or other payment as described in section 12(7) is made,is not performed through that business or permanent establishment, or the giving of the guarantee relating to the loan or indebtedness concerned as described in section 12(6)(a) is not effectively connected with that business or permanent establishment.(5A) An approval of a shipping financing arrangement enterprise for the purposes of subsection (5) may be granted between 1 January 2025 and 31 December 2031 (both dates inclusive), and is —(a)subject to any condition specified by the Minister or authorised body; and(b)for a period not exceeding 5 years specified by the Minister or authorised body, except that the Minister or authorised body may extend the period for any further periods that the Minister or authorised body thinks fit.(5B) A notification made under subsection (4) for the purposes of subsection (5) may be made to take effect from (and including) 1 January 2025.(5C) For the purposes of subsections (5), (5A) and this subsection —(g)in subsections (12A), (12B)(a) and (12C), replace “2026” with “2031”;(h)in subsection (12A)(c), delete “incorporated in Singapore”; and(i)after subsection (13A), insert —“(14) Any order made under subsection (12) in relation to the following income may be made to take effect on 19 February 2025:(a)any income received in Singapore by a company resident in Singapore, the share capital of which is 100% owned (whether directly or indirectly) by the trustee of a real estate investment trust;(b)any rental income or property‑related income (within the meaning of that order) or income ancillary to any such income, received in Singapore by —(i)the trustee of a real estate investment trust who is resident in Singapore; or (ii)the trustee of a sub‑trust of a real estate investment trust who is resident in Singapore, where all rights or interests in the property of the sub‑trust are held for the benefit of the beneficiaries of the real estate investment trust,where the income is derived from the direct holding of immovable property situated outside Singapore by the trustee in sub‑paragraph (i) or (ii), as the case may be.(14A) Any order made under subsection (12) in relation to income received by a person resident in Singapore, connected with any loan taken or debt securities issued for the purpose of acquiring, developing, investing in, owning or operating an offshore infrastructure asset or project, may be made to take effect from (and including) 1 January 2026.”.

“approved special purpose vehicle”, in relation to a shipping financing arrangement enterprise, means a company, a partnership or a registered business trust that undertakes or intends to undertake any activity mentioned in paragraph (a) or (b) of the definition of “shipping financing arrangement enterprise” involving ships or containers controlled and managed by the enterprise, and is approved by the Minister or authorised body to be an approved special purpose vehicle of the enterprise;

“finance leasing” has the meaning given by section 13A(16);

“shipping financing arrangement enterprise” means —(a)a company resident in Singapore that owns or operates a ship, or intends to own or operate a ship, either directly or using an approved special purpose vehicle; or(b)a company incorporated and resident in Singapore, a partnership registered under any written law in Singapore or a registered business trust that undertakes or intends to undertake, either directly or using an approved special purpose vehicle, the chartering or leasing (including by finance leasing) of a ship, or a container as defined under section 43P(7).”;

“(2K) Rules made under section 7(1) to prescribe the Internet website mentioned in subsection (1)(zpa) may be made to take effect from (and including) 1 January 2013.

Rules made under section 7(1) to prescribe the Internet website mentioned in subsection (1)(zv) may be made to take effect from (and including) 10 March 2025.”;

“(5) A notification made under subsection (4) may exempt from tax any payment in the nature of any income referred to in section 12(6) or (7) that is made —(a)by a shipping financing arrangement enterprise that is approved by the Minister or an authorised body for the purposes of this subsection; and(b)to a person that is not resident in Singapore and either —(i)does not (alone or in association with others) carry on a business in Singapore and does not have a permanent establishment in Singapore; or (ii)carries on a business in Singapore (alone or in association with others) or has a permanent establishment in Singapore, but —(A)the arrangement, management or service relating to the loan or indebtedness concerned as described in section 12(6)(a); or(B)the act for which the royalty or other payment as described in section 12(7) is made,is not performed through that business or permanent establishment, or the giving of the guarantee relating to the loan or indebtedness concerned as described in section 12(6)(a) is not effectively connected with that business or permanent establishment.

An approval of a shipping financing arrangement enterprise for the purposes of subsection (5) may be granted between 1 January 2025 and 31 December 2031 (both dates inclusive), and is —(a)subject to any condition specified by the Minister or authorised body; and(b)for a period not exceeding 5 years specified by the Minister or authorised body, except that the Minister or authorised body may extend the period for any further periods that the Minister or authorised body thinks fit.

A notification made under subsection (4) for the purposes of subsection (5) may be made to take effect from (and including) 1 January 2025.

For the purposes of subsections (5), (5A) and this subsection —

“(14) Any order made under subsection (12) in relation to the following income may be made to take effect on 19 February 2025:(a)any income received in Singapore by a company resident in Singapore, the share capital of which is 100% owned (whether directly or indirectly) by the trustee of a real estate investment trust;(b)any rental income or property‑related income (within the meaning of that order) or income ancillary to any such income, received in Singapore by —(i)the trustee of a real estate investment trust who is resident in Singapore; or (ii)the trustee of a sub‑trust of a real estate investment trust who is resident in Singapore, where all rights or interests in the property of the sub‑trust are held for the benefit of the beneficiaries of the real estate investment trust,where the income is derived from the direct holding of immovable property situated outside Singapore by the trustee in sub‑paragraph (i) or (ii), as the case may be.

Any order made under subsection (12) in relation to income received by a person resident in Singapore, connected with any loan taken or debt securities issued for the purpose of acquiring, developing, investing in, owning or operating an offshore infrastructure asset or project, may be made to take effect from (and including) 1 January 2026.”.

Section 13(1)(zv), (zx) and (zy) of the ITA applies for the year of assessment 2026 and any subsequent year of assessment.

Section 13(1)(zw) of the ITA applies for the year of assessment 2027 and any subsequent year of assessment.

In the ITA, in section 13A —(a)in subsections (1CH)(a) and (1CI)(a), after “offshore renewable energy activity”, insert “(carried out before 19 February 2025), renewable energy activity (carried out on or after 19 February 2025)”;(b)replace subsection (1CJ) with —“(1CJ) The income of a shipping enterprise mentioned in this section includes the following income derived by it from foreign exchange and risk management activities that are carried out in connection with and incidental to an activity mentioned in subsection (1CH) or (1CI):(a)where the activity relates to offshore renewable energy activity — such income that is derived between 25 March 2016 and 18 February 2025 (both dates inclusive);(b)where the activity relates to renewable energy activity — such income that is derived on or after 19 February 2025;(c)where the activity relates to offshore mineral activity — such income that is derived on or after 25 March 2016.”;(c)in subsection (3)(b), replace “or (1CK)” with “, (1CK) or (1CL)”;(d)in subsection (16), in the definitions of “holding” and “mobilisation”, after “offshore renewable energy activity”, insert “, renewable energy activity”; and(e)in subsection (16), in the definition of “operation”, in paragraph (a), replace sub‑paragraph (v) with —“(v)the use, between 25 March 2016 and 18 February 2025 (both dates inclusive), outside the limits of the port of Singapore of the ship for offshore renewable energy activity;(va)the use, on or after 19 February 2025, outside the limits of the port of Singapore of the ship for renewable energy activity;(vb)the use, on or after 25 March 2016, outside the limits of the port of Singapore of the ship for offshore mineral activity; or”.

“(1CJ) The income of a shipping enterprise mentioned in this section includes the following income derived by it from foreign exchange and risk management activities that are carried out in connection with and incidental to an activity mentioned in subsection (1CH) or (1CI):(a)where the activity relates to offshore renewable energy activity — such income that is derived between 25 March 2016 and 18 February 2025 (both dates inclusive);(b)where the activity relates to renewable energy activity — such income that is derived on or after 19 February 2025;(c)where the activity relates to offshore mineral activity — such income that is derived on or after 25 March 2016.”;

—(1) In the ITA, in section 13E —(a)in subsection (1)(l), replace “on or after 25 March 2016” with “during the period from 25 March 2016 to 18 February 2025 (both dates inclusive)”;(b)in subsection (1)(l)(i) and (ii), delete “or offshore mineral activity”;(c)in subsection (1)(l)(i), replace “and” at the end with “or”;(d)in subsection (1), after paragraph (l), insert —“(la)on or after 19 February 2025 from —(i)the operation outside the limits of the port of Singapore of any foreign ship for renewable energy activity; or(ii)the charter of any foreign ship for renewable energy activity to any person, where such ship is used by the person for the person’s operation outside the limits of the port of Singapore;(lb)on or after 25 March 2016 from —(i)the operation outside the limits of the port of Singapore of any foreign ship for offshore mineral activity; or(ii)the charter of any foreign ship for offshore mineral activity to any person, where such ship is used by the person for the person’s operation outside the limits of the port of Singapore;”;(e)in subsection (1)(m), replace “on or after 25 March 2016” with “during the period from 25 March 2016 to 18 February 2025 (both dates inclusive)”;(f)in subsection (1)(m)(i), (ii) and (iii)(A), delete “or offshore mineral activity”;(g)in subsection (1), after paragraph (m), insert —“(ma)on or after 19 February 2025 from —(i)the sale of a foreign ship used for renewable energy activity;(ii)the assignment to another of all its rights as the buyer under a contract for the construction of a ship for renewable energy activity that, at the time of assignment, is intended to be a foreign ship to be used for that activity or any prescribed purpose; or(iii)the sale of all of the issued ordinary shares in a special purpose company of the approved international shipping enterprise where, at the time of the sale of the shares, the special purpose company —(A)owns any foreign ship that is used for renewable energy activity; or(B)is the buyer under a contract for the construction of a foreign ship for that activity and that is intended to be used for that activity or any prescribed purpose;(mb)on or after 25 March 2016 from —(i)the sale of a foreign ship used for offshore mineral activity;(ii)the assignment to another of all its rights as the buyer under a contract for the construction of a ship for offshore mineral activity that, at the time of assignment, is intended to be a foreign ship to be used for that activity or any prescribed purpose; or(iii)the sale of all of the issued ordinary shares in a special purpose company of the approved international shipping enterprise where, at the time of the sale of the shares, the special purpose company —(A)owns any foreign ship that is used for offshore mineral activity; or(B)is the buyer under a contract for the construction of a foreign ship for that activity and that is intended to be used for that activity or any prescribed purpose;”;(h)in subsection (1)(n), replace “on or after 25 March 2016” with “during the period from 25 March 2016 to 18 February 2025 (both dates inclusive)”;(i)in subsection (1)(n)(i), delete “, or offshore mineral activity,”;(j)in subsection (1), after paragraph (n), insert —“(na)on or after 19 February 2025 from —(i)any mobilisation or holding of any ship used or to be used for renewable energy activity outside the limits of the port of Singapore; or(ii)the demobilisation of any ship after it has been so used,where the mobilisation, holding or demobilisation is undertaken by the approved international shipping enterprise itself using a foreign ship;(nb)on or after 25 March 2016 from —(i)any mobilisation or holding of any ship used or to be used for offshore mineral activity outside the limits of the port of Singapore; or(ii)the demobilisation of any ship after it has been so used,where the mobilisation, holding or demobilisation is undertaken by the approved international shipping enterprise itself using a foreign ship;”;(k)in subsection (1)(o), replace “on or after 25 March 2016” with “during the period from 25 March 2016 to 18 February 2025 (both dates inclusive)”;(l)in subsection (1)(o)(i), delete “, or offshore mineral activity,”;(m)in subsection (1), after paragraph (o), insert —“(oa)on or after 19 February 2025 from —(i)any mobilisation or holding of a foreign ship owned or operated by the approved international shipping enterprise and used or to be used for renewable energy activity outside the limits of the port of Singapore; or(ii)the demobilisation of a foreign ship owned or operated by the approved international shipping enterprise after it has been so used;(ob)on or after 25 March 2016 from —(i)any mobilisation or holding of a foreign ship owned or operated by the approved international shipping enterprise and used or to be used for offshore mineral activity outside the limits of the port of Singapore; or(ii)the demobilisation of a foreign ship owned or operated by the approved international shipping enterprise after it has been so used;”;(n)in subsection (1)(p), replace “(n) or (o)” with “(lb), (n), (nb), (o) or (ob)”;(o)in subsection (1)(r), replace sub‑paragraph (iv) with —“(iv)the finance leasing of any foreign ship to any person where the ship is used by the person for any of the following activities outside the limits of the port of Singapore:(A)offshore renewable energy activity carried out before 19 February 2025; (B)renewable energy activity carried out on or after 19 February 2025; or (C)offshore mineral activity;”;(p)in subsection (1)(s), delete “and” at the end;(q)in subsection (1)(t), replace the full‑stop at the end with “; and”;(r)in subsection (1), after paragraph (t), insert —“(u)on or after 19 February 2025 from foreign exchange and risk management activities which are carried out in connection with and incidental to an activity mentioned in paragraph (la), (na) or (oa).”;(s)in subsection (1AC), replace “Subsection (1)(m) does” with “Subsection (1)(m), (ma) and (mb) does”;(t)in subsection (1AC)(b), replace “used for either of those activities” with “used for offshore renewable energy activity, renewable energy activity or offshore mineral activity”;(u)in subsection (1AC)(b), replace “foreign ships for either of those activities” with “foreign ships for any of those activities”;(v)in subsection (2A), replace “2026” with “2031”;(w)in subsection (4), replace “(l) and (n) to (s)” with “(lb), (n) to (s) and (u)”;(x)in subsection (4A), replace “in subsection (1)(g) or (m)” with “in subsection (1)(g), (m), (ma) or (mb)”;(y)in subsection (4A), replace “either subsection (1)(g) or (m)” with “subsection (1)(g), (m), (ma) or (mb)”;(z)in subsection (6), in the definition of “special purpose company”, in paragraph (c), replace “on or after 25 March 2016” with “during the period from 25 March 2016 to 18 February 2025 (both dates inclusive)”;(za)in subsection (6), in the definition of “special purpose company”, in paragraph (c), delete “or” at the end;(zb)in subsection (6), in the definition of “special purpose company”, after paragraph (c), insert —“(ca)any operation or activity mentioned in subsection (1)(la), (na) or (oa) that takes place on or after 19 February 2025;(cb)any operation or activity mentioned in subsection (1)(lb), (nb) or (ob) that takes place on or after 25 March 2016; or”;(zc)in subsection (7)(a), after “approved company”, insert “other than one mentioned in paragraph (b)”;(zd)in subsection (7)(a)(i) and (d)(i), delete “incorporated and”; and(ze)in subsection (7)(d)(i), after “Singapore”, insert “and is not one mentioned in sub‑paragraph (ii)”.(2) In the ITA, in section 13E —(a)in subsection (1)(t) (as amended by subsection (1)(q)), delete “and” at the end;(b)in subsection (1)(u) (as inserted by subsection (1)(r)), replace the full‑stop at the end with “; and”;(c)in subsection (1), after paragraph (u) (as inserted by subsection (1)(r)), insert —“(v)on or after the date of commencement of section 7(2)(c) of the Finance (Income Taxes) Act 2025, from foreign exchange and risk management activities which are carried out in connection with and incidental to an activity mentioned in paragraph (t).”; and(d)in subsection (4) (as amended by subsection (1)(w)), replace “, (n) to (s) and (u)” with “and (n) to (v)”.

In the ITA, in section 13E —(a)in subsection (1)(l), replace “on or after 25 March 2016” with “during the period from 25 March 2016 to 18 February 2025 (both dates inclusive)”;(b)in subsection (1)(l)(i) and (ii), delete “or offshore mineral activity”;(c)in subsection (1)(l)(i), replace “and” at the end with “or”;(d)in subsection (1), after paragraph (l), insert —“(la)on or after 19 February 2025 from —(i)the operation outside the limits of the port of Singapore of any foreign ship for renewable energy activity; or(ii)the charter of any foreign ship for renewable energy activity to any person, where such ship is used by the person for the person’s operation outside the limits of the port of Singapore;(lb)on or after 25 March 2016 from —(i)the operation outside the limits of the port of Singapore of any foreign ship for offshore mineral activity; or(ii)the charter of any foreign ship for offshore mineral activity to any person, where such ship is used by the person for the person’s operation outside the limits of the port of Singapore;”;(e)in subsection (1)(m), replace “on or after 25 March 2016” with “during the period from 25 March 2016 to 18 February 2025 (both dates inclusive)”;(f)in subsection (1)(m)(i), (ii) and (iii)(A), delete “or offshore mineral activity”;(g)in subsection (1), after paragraph (m), insert —“(ma)on or after 19 February 2025 from —(i)the sale of a foreign ship used for renewable energy activity;(ii)the assignment to another of all its rights as the buyer under a contract for the construction of a ship for renewable energy activity that, at the time of assignment, is intended to be a foreign ship to be used for that activity or any prescribed purpose; or(iii)the sale of all of the issued ordinary shares in a special purpose company of the approved international shipping enterprise where, at the time of the sale of the shares, the special purpose company —(A)owns any foreign ship that is used for renewable energy activity; or(B)is the buyer under a contract for the construction of a foreign ship for that activity and that is intended to be used for that activity or any prescribed purpose;(mb)on or after 25 March 2016 from —(i)the sale of a foreign ship used for offshore mineral activity;(ii)the assignment to another of all its rights as the buyer under a contract for the construction of a ship for offshore mineral activity that, at the time of assignment, is intended to be a foreign ship to be used for that activity or any prescribed purpose; or(iii)the sale of all of the issued ordinary shares in a special purpose company of the approved international shipping enterprise where, at the time of the sale of the shares, the special purpose company —(A)owns any foreign ship that is used for offshore mineral activity; or(B)is the buyer under a contract for the construction of a foreign ship for that activity and that is intended to be used for that activity or any prescribed purpose;”;(h)in subsection (1)(n), replace “on or after 25 March 2016” with “during the period from 25 March 2016 to 18 February 2025 (both dates inclusive)”;(i)in subsection (1)(n)(i), delete “, or offshore mineral activity,”;(j)in subsection (1), after paragraph (n), insert —“(na)on or after 19 February 2025 from —(i)any mobilisation or holding of any ship used or to be used for renewable energy activity outside the limits of the port of Singapore; or(ii)the demobilisation of any ship after it has been so used,where the mobilisation, holding or demobilisation is undertaken by the approved international shipping enterprise itself using a foreign ship;(nb)on or after 25 March 2016 from —(i)any mobilisation or holding of any ship used or to be used for offshore mineral activity outside the limits of the port of Singapore; or(ii)the demobilisation of any ship after it has been so used,where the mobilisation, holding or demobilisation is undertaken by the approved international shipping enterprise itself using a foreign ship;”;(k)in subsection (1)(o), replace “on or after 25 March 2016” with “during the period from 25 March 2016 to 18 February 2025 (both dates inclusive)”;(l)in subsection (1)(o)(i), delete “, or offshore mineral activity,”;(m)in subsection (1), after paragraph (o), insert —“(oa)on or after 19 February 2025 from —(i)any mobilisation or holding of a foreign ship owned or operated by the approved international shipping enterprise and used or to be used for renewable energy activity outside the limits of the port of Singapore; or(ii)the demobilisation of a foreign ship owned or operated by the approved international shipping enterprise after it has been so used;(ob)on or after 25 March 2016 from —(i)any mobilisation or holding of a foreign ship owned or operated by the approved international shipping enterprise and used or to be used for offshore mineral activity outside the limits of the port of Singapore; or(ii)the demobilisation of a foreign ship owned or operated by the approved international shipping enterprise after it has been so used;”;(n)in subsection (1)(p), replace “(n) or (o)” with “(lb), (n), (nb), (o) or (ob)”;(o)in subsection (1)(r), replace sub‑paragraph (iv) with —“(iv)the finance leasing of any foreign ship to any person where the ship is used by the person for any of the following activities outside the limits of the port of Singapore:(A)offshore renewable energy activity carried out before 19 February 2025; (B)renewable energy activity carried out on or after 19 February 2025; or (C)offshore mineral activity;”;(p)in subsection (1)(s), delete “and” at the end;(q)in subsection (1)(t), replace the full‑stop at the end with “; and”;(r)in subsection (1), after paragraph (t), insert —“(u)on or after 19 February 2025 from foreign exchange and risk management activities which are carried out in connection with and incidental to an activity mentioned in paragraph (la), (na) or (oa).”;(s)in subsection (1AC), replace “Subsection (1)(m) does” with “Subsection (1)(m), (ma) and (mb) does”;(t)in subsection (1AC)(b), replace “used for either of those activities” with “used for offshore renewable energy activity, renewable energy activity or offshore mineral activity”;(u)in subsection (1AC)(b), replace “foreign ships for either of those activities” with “foreign ships for any of those activities”;(v)in subsection (2A), replace “2026” with “2031”;(w)in subsection (4), replace “(l) and (n) to (s)” with “(lb), (n) to (s) and (u)”;(x)in subsection (4A), replace “in subsection (1)(g) or (m)” with “in subsection (1)(g), (m), (ma) or (mb)”;(y)in subsection (4A), replace “either subsection (1)(g) or (m)” with “subsection (1)(g), (m), (ma) or (mb)”;(z)in subsection (6), in the definition of “special purpose company”, in paragraph (c), replace “on or after 25 March 2016” with “during the period from 25 March 2016 to 18 February 2025 (both dates inclusive)”;(za)in subsection (6), in the definition of “special purpose company”, in paragraph (c), delete “or” at the end;(zb)in subsection (6), in the definition of “special purpose company”, after paragraph (c), insert —“(ca)any operation or activity mentioned in subsection (1)(la), (na) or (oa) that takes place on or after 19 February 2025;(cb)any operation or activity mentioned in subsection (1)(lb), (nb) or (ob) that takes place on or after 25 March 2016; or”;(zc)in subsection (7)(a), after “approved company”, insert “other than one mentioned in paragraph (b)”;(zd)in subsection (7)(a)(i) and (d)(i), delete “incorporated and”; and(ze)in subsection (7)(d)(i), after “Singapore”, insert “and is not one mentioned in sub‑paragraph (ii)”.

In the ITA, in section 13E —(a)in subsection (1)(t) (as amended by subsection (1)(q)), delete “and” at the end;(b)in subsection (1)(u) (as inserted by subsection (1)(r)), replace the full‑stop at the end with “; and”;(c)in subsection (1), after paragraph (u) (as inserted by subsection (1)(r)), insert —“(v)on or after the date of commencement of section 7(2)(c) of the Finance (Income Taxes) Act 2025, from foreign exchange and risk management activities which are carried out in connection with and incidental to an activity mentioned in paragraph (t).”; and(d)in subsection (4) (as amended by subsection (1)(w)), replace “, (n) to (s) and (u)” with “and (n) to (v)”.

In the ITA, in section 13P —(a)replace subsection (1D) with —“(1D) Subsection (1)(ca) and (cc) does not apply to —(a)income derived between 12 December 2018 and 18 February 2025 (both dates inclusive) from the chartering or finance leasing of a seagoing ship that is acquired by the approved shipping investment enterprise or the approved related party by way of a finance lease entered into with an entity that is not an approved related party; or(b)income derived on or after 19 February 2025 from the chartering or finance leasing of a seagoing ship that is acquired by the approved shipping investment enterprise or the approved related party by way of a finance lease not treated as a sale under section 10C, entered into with an entity that is not an approved related party.”;(b)in subsections (2) and (3)(b), replace “2026” with “2031”; and(c)in subsection (4)(b), after “offshore renewable energy activity”, insert “, renewable energy activity”.

“(1D) Subsection (1)(ca) and (cc) does not apply to —(a)income derived between 12 December 2018 and 18 February 2025 (both dates inclusive) from the chartering or finance leasing of a seagoing ship that is acquired by the approved shipping investment enterprise or the approved related party by way of a finance lease entered into with an entity that is not an approved related party; or(b)income derived on or after 19 February 2025 from the chartering or finance leasing of a seagoing ship that is acquired by the approved shipping investment enterprise or the approved related party by way of a finance lease not treated as a sale under section 10C, entered into with an entity that is not an approved related party.”;

In the ITA, in section 13U(5), in the definition of “eligible SPV”, in paragraph (d), replace “or an approved foreign government‑owned entity” with “, an approved foreign government‑owned entity, a prescribed international organisation or an approved international organisation”.

In the ITA, in section 13W —(a)in the section heading, after “shares”, insert “or preference shares”;(b)in subsection (1), replace “the divesting company” wherever it appears with “divesting company A”;(c)in subsection (1), replace “the investee company” with “investee company B”;(d)in subsection (1)(a), replace “2027” with “2025”;(e)in subsection (1)(b), replace “that investee company” with “investee company B”;(f)after subsection (1), insert —“(1A) There is exempt from tax any gains or profits derived by a company (called in this section divesting company A1) from the disposal of ordinary shares or preference shares (or both) in another company (called in this section investee company B1) which are legally and beneficially owned by divesting company A1 immediately before the disposal, if —(a)the disposal is made on or after 1 January 2026; and(b)the disposal is made after divesting company A1 has, at all times during a continuous period of at least 24 months ending on the date immediately before the date of disposal of such shares —(i)legally and beneficially owned at least 20% of the ordinary shares in investee company B1; or(ii)legally and beneficially owned ordinary shares or preference shares (or both) in investee company B1 the value of which is at least 20% of the total amount of paid‑up share capital of ordinary shares and preference shares in investee company B1 under the applicable accounting principles.(1B) There is exempt from tax any gains or profits derived by a company (called in this section divesting company A2) from the disposal of ordinary shares or preference shares (or both) in another company (called in this section investee company B2) which are legally and beneficially owned by divesting company A2 immediately before the disposal (called in this section the subject shares), if —(a)the disposal is made on or after 1 January 2026; (b)the subject shares were held by divesting company A2 for a continuous period of at least 24 months ending on the date immediately before the date of the disposal; and(c)at the beginning (called the start date) of the period of 24 months ending on the date immediately before the date of the disposal, divesting company A2 together with one or more companies in the same group as divesting company A2 —(i)legally and beneficially owned ordinary shares in investee company B2 (which included the subject shares) that (in total) represent at least 20% of the ordinary shares in investee company B2 as of the start date; or(ii)legally and beneficially owned ordinary shares or preference shares (or both) in investee company B2 (which included the subject shares) the value of which is at least 20% of the total amount of paid‑up share capital of ordinary shares and preference shares in investee company B2 as of the start date under the applicable accounting principles,and divesting company A2 and the other company or companies in the same group did not dispose of any of those shares during that period which resulted in the legal and beneficial ownership described in sub‑paragraph (i) or (ii) (as the case may be) falling below the percentage specified in that sub‑paragraph.(1C) For the purpose of subsection (1B) —(a)shares in investee company B2 are treated as having been disposed of by a company on a first‑in‑first‑out basis; and(b)companies are in the same group if —(i)more than 50% of the total number of issued ordinary shares in one company are beneficially owned by the other company; or(ii)more than 50% of the total number of issued ordinary shares in each of those companies are beneficially owned by a common company.(1D) For the purpose of subsection (1C)(b), if —(a)a company beneficially owns (including by virtue of one or more applications of this subsection) issued ordinary shares in another company (called in this subsection a 1st level company); and(b)the 1st level company beneficially owns issued ordinary shares in another company (called in this subsection a 2nd level company),then the firstmentioned company is taken to beneficially own issued ordinary shares of the 2nd level company; and the percentage of such beneficial ownership is computed by the formula A × B, where —(c)A is the percentage which the number of issued ordinary shares of the 1st level company beneficially owned by the firstmentioned company bears to the total number of all issued ordinary shares of the 1st level company; and(d)B is the percentage which the number of issued ordinary shares of the 2nd level company beneficially owned by the 1st level company bears to the total number of all issued ordinary shares of the 2nd level company.(1E) Any reference to divesting company A2 in subsection (1B) does not include a registered business trust (despite section 36B(1)) or VCC.”;(g)in subsection (2), after “Subsection (1)”, insert “, (1A) or (1B)”;(h)in subsections (2), (3), (5) and (7), replace “the divesting company” wherever it appears with “divesting company A, A1 or A2”;(i)in the following provisions, after “subsection (1)”, insert “, (1A) or (1B)”:Subsection (3)Subsection (5)(a)Subsection (7)(a);(j)replace subsection (4) with —“(4) For the purposes of subsection (1), (1A) or (1B), a company (X) is treated as legally and beneficially owning any shares in another company (Y) during the borrowing period when the legal interest in those shares had been transferred by X to another under a securities lending or repurchase arrangement.”;(k)in subsection (9), after the definition of “activity of holding immovable properties”, insert —“ “applicable accounting principles”, in relation to a company, means —(a)the accounting principles adopted by the company; or(b)if the company is not required to comply with any accounting principles in preparing its financial statements — the International Financial Reporting Standards;”; and(l)in subsection (9), after the definitions of “FRS 109” and “SFRS(I) 9”, insert —“ “preference shares” means only preference shares that are accounted for as equity by the investee company under the applicable accounting principles;”.

“(1A) There is exempt from tax any gains or profits derived by a company (called in this section divesting company A1) from the disposal of ordinary shares or preference shares (or both) in another company (called in this section investee company B1) which are legally and beneficially owned by divesting company A1 immediately before the disposal, if —(a)the disposal is made on or after 1 January 2026; and(b)the disposal is made after divesting company A1 has, at all times during a continuous period of at least 24 months ending on the date immediately before the date of disposal of such shares —(i)legally and beneficially owned at least 20% of the ordinary shares in investee company B1; or(ii)legally and beneficially owned ordinary shares or preference shares (or both) in investee company B1 the value of which is at least 20% of the total amount of paid‑up share capital of ordinary shares and preference shares in investee company B1 under the applicable accounting principles.

There is exempt from tax any gains or profits derived by a company (called in this section divesting company A2) from the disposal of ordinary shares or preference shares (or both) in another company (called in this section investee company B2) which are legally and beneficially owned by divesting company A2 immediately before the disposal (called in this section the subject shares), if —(a)the disposal is made on or after 1 January 2026; (b)the subject shares were held by divesting company A2 for a continuous period of at least 24 months ending on the date immediately before the date of the disposal; and(c)at the beginning (called the start date) of the period of 24 months ending on the date immediately before the date of the disposal, divesting company A2 together with one or more companies in the same group as divesting company A2 —(i)legally and beneficially owned ordinary shares in investee company B2 (which included the subject shares) that (in total) represent at least 20% of the ordinary shares in investee company B2 as of the start date; or(ii)legally and beneficially owned ordinary shares or preference shares (or both) in investee company B2 (which included the subject shares) the value of which is at least 20% of the total amount of paid‑up share capital of ordinary shares and preference shares in investee company B2 as of the start date under the applicable accounting principles,and divesting company A2 and the other company or companies in the same group did not dispose of any of those shares during that period which resulted in the legal and beneficial ownership described in sub‑paragraph (i) or (ii) (as the case may be) falling below the percentage specified in that sub‑paragraph.

For the purpose of subsection (1B) —(a)shares in investee company B2 are treated as having been disposed of by a company on a first‑in‑first‑out basis; and(b)companies are in the same group if —(i)more than 50% of the total number of issued ordinary shares in one company are beneficially owned by the other company; or(ii)more than 50% of the total number of issued ordinary shares in each of those companies are beneficially owned by a common company.

For the purpose of subsection (1C)(b), if —(a)a company beneficially owns (including by virtue of one or more applications of this subsection) issued ordinary shares in another company (called in this subsection a 1st level company); and(b)the 1st level company beneficially owns issued ordinary shares in another company (called in this subsection a 2nd level company),then the firstmentioned company is taken to beneficially own issued ordinary shares of the 2nd level company; and the percentage of such beneficial ownership is computed by the formula A × B, where —(c)A is the percentage which the number of issued ordinary shares of the 1st level company beneficially owned by the firstmentioned company bears to the total number of all issued ordinary shares of the 1st level company; and(d)B is the percentage which the number of issued ordinary shares of the 2nd level company beneficially owned by the 1st level company bears to the total number of all issued ordinary shares of the 2nd level company.

Any reference to divesting company A2 in subsection (1B) does not include a registered business trust (despite section 36B(1)) or VCC.”;

“(4) For the purposes of subsection (1), (1A) or (1B), a company (X) is treated as legally and beneficially owning any shares in another company (Y) during the borrowing period when the legal interest in those shares had been transferred by X to another under a securities lending or repurchase arrangement.”;

—(1) In the ITA, in section 14 —(a)in subsection (1), replace paragraph (d) (including the proviso) with —“(d)any bad debt incurred in any trade, business, profession or vocation that became bad during the period for which the income is being ascertained, and any of the following to the extent that it has been estimated, to the Comptroller’s satisfaction, to have become bad during that period: (i)any doubtful debt;(ii)any other debt for which provisions have been made for impairment losses or expected credit losses (called in this paragraph provisioned debt),even if the bad debt, doubtful debt or provisioned debt was due and payable before the commencement of that period, but only if —(iii)all sums recovered during that period on account of amounts previously written off or allowed in respect of bad debts, doubtful debts or provisioned debts (other than debts incurred before the commencement of the basis period for the first year of assessment under this Act) are for the purposes of this Act treated as receipts of the trade, business, profession or vocation for that period; and(iv)the bad debts, doubtful debts or provisioned debts in respect of which a deduction is claimed were included as a trading receipt in the income of the year within which they were incurred;”;(b)after subsection (7), insert —“(7A) Despite subsection (1), no deduction is allowed to any person under that subsection in respect of any expenditure for which a deduction is allowed to that person under section 14ZJ.”; and(c)in subsection (8), after the definition of “deductible”, insert —“ “expected credit loss” has the meaning given by section 14G(7);”.(2) The amendments to section 14(1) and (8) of the ITA apply for the year of assessment 2027 and any subsequent year of assessment.

In the ITA, in section 14 —(a)in subsection (1), replace paragraph (d) (including the proviso) with —“(d)any bad debt incurred in any trade, business, profession or vocation that became bad during the period for which the income is being ascertained, and any of the following to the extent that it has been estimated, to the Comptroller’s satisfaction, to have become bad during that period: (i)any doubtful debt;(ii)any other debt for which provisions have been made for impairment losses or expected credit losses (called in this paragraph provisioned debt),even if the bad debt, doubtful debt or provisioned debt was due and payable before the commencement of that period, but only if —(iii)all sums recovered during that period on account of amounts previously written off or allowed in respect of bad debts, doubtful debts or provisioned debts (other than debts incurred before the commencement of the basis period for the first year of assessment under this Act) are for the purposes of this Act treated as receipts of the trade, business, profession or vocation for that period; and(iv)the bad debts, doubtful debts or provisioned debts in respect of which a deduction is claimed were included as a trading receipt in the income of the year within which they were incurred;”;(b)after subsection (7), insert —“(7A) Despite subsection (1), no deduction is allowed to any person under that subsection in respect of any expenditure for which a deduction is allowed to that person under section 14ZJ.”; and(c)in subsection (8), after the definition of “deductible”, insert —“ “expected credit loss” has the meaning given by section 14G(7);”.

“(7A) Despite subsection (1), no deduction is allowed to any person under that subsection in respect of any expenditure for which a deduction is allowed to that person under section 14ZJ.”; and

The amendments to section 14(1) and (8) of the ITA apply for the year of assessment 2027 and any subsequent year of assessment.

In the ITA, in section 14B, in the following provisions, replace “2025” with “2030”: Subsection (2AA) Subsection (2AB) Subsection (12).

In the ITA, after section 14EA, insert —“Deduction for payment under innovation cost‑sharing agreement14EB.—(1) Subject to this section, where a company carrying on a trade or business has made, in the period specified under subsection (2)(b) for that agreement, any payment under an innovation cost‑sharing agreement approved by the Minister or an authorised body on or after 19 February 2025 in respect of one or more qualifying innovation activities carried out under that agreement, there is allowed a deduction of the amount of such payment for the purpose of ascertaining the income of the company.(2) The Minister or authorised body may —(a)impose such conditions as the Minister or authorised body thinks fit when approving an innovation cost‑sharing agreement; and(b)specify the period during which any payment made under the innovation cost‑sharing agreement is allowed a deduction under this section.(3) The Minister or authorised body may approve an innovation cost‑sharing agreement only if —(a)the agreement provides that any benefit arising from the agreement accrues (whether wholly or partly) to the company;(b)there is an undertaking by the company that at least one of the qualifying innovation activities is to be carried out by or on behalf of the company (whether wholly or partly) in Singapore; and(c)such other requirements as the Minister or authorised body specifies, are satisfied.(4) A deduction is not allowed under subsection (1) if —(a)benefit arising from the approved innovation cost‑sharing agreement (if any) does not accrue (whether wholly or partly) to the company; or(b)no qualifying innovation activity is carried out in Singapore by or on behalf of the company.(5) No approval under this section may be granted after 31 December 2030.(6) If any benefit that arose from an approved innovation cost‑sharing agreement during the period specified for it under subsection (2)(b) is sold, assigned or otherwise disposed of at any time by the company to which a deduction has been allowed under subsection (1), the lower of the following is treated as a trading receipt of the company’s trade or business for the year of assessment which relates to the basis period in which the sale, assignment or disposal occurs:(a)the amount of deduction that has been allowed under subsection (1) that is attributable to the benefit, to the extent that this amount of deduction has not been previously treated as a trading receipt under this subsection;(b)the amount or value of the consideration received by the company from the sale, assignment or disposal.(7) If, for any reason, the deduction cannot be attributed to that benefit, the full amount of the deduction that has been allowed under subsection (1) is treated as being attributable to that benefit. (8) A sale, assignment or disposal of any benefit that occurs after the date on which the company permanently ceases its trade or business is treated as having occurred immediately before the cessation.(9) The payment mentioned in subsection (1) does not include any payment to the extent that it is or is to be subsidised by grants or subsidies from the Government or a statutory board.(10) Where a company to which a deduction has been allowed for any payment made under this section becomes entitled to any royalty or other payments (in one lump sum or otherwise) for the use of or right to use any technology, know‑how or intellectual property developed from a qualifying innovation activity carried out under the approved innovation cost‑sharing agreement, such royalty or payments are treated as income of that company that is derived from Singapore for the year of assessment which relates to the basis period in which that company becomes entitled to the royalty or payments, as the case may be.(11) Where an innovation cost‑sharing agreement has been approved by the Minister or authorised body for the purposes of this section, then during the period specified under subsection (2)(b) for the agreement —(a)a company is only allowed a deduction under this section in respect of any payment made under the agreement; and(b)no deduction or allowance is allowed under section 14A, 14C, 14D, 14EA, 14U or 19B in respect of such payment despite anything in that section. (12) For the purposes of this section, any payment made by a company prior to the commencement of that company’s trade or business is treated as having been made by that company on the first day that the company carries on that trade or business, but a deduction for such payment is subject to section 14X.(13) In this section —(a)a reference to a payment made by a company under an innovation cost‑sharing agreement is a reference to the expenditure that is allocated to the company to bear under the agreement, and the time the payment for any part of the expenditure becomes payable by the company or (if no such payment is needed) the time of the allocation, is treated as the time the payment is made; and(b)a reference to a payment made by a company under an innovation cost‑sharing agreement excludes any payment for the right to be a party to the agreement.(14) In this section —“benefit”, in relation to an innovation cost‑sharing agreement, means —(a)any right arising from the agreement;(b)any technology, know‑how, intellectual property or software developed from any qualifying innovation activity carried out under the agreement; or(c)any asset acquired under the agreement;“innovation cost‑sharing agreement” means any agreement or arrangement made by 2 or more related parties to share the expenditure of qualifying innovation activities to be carried out under the agreement or arrangement (and no other expenditure);“qualifying innovation activity” means an activity falling within any of the following categories of activities, being categories specified in the document entitled “Oslo Manual 2018 — Guidelines for Collecting, Reporting and Using Data on Innovation” that is published by the Organisation for Economic Co‑operation and Development on 22 October 2018:(a)research and experimental development activities;(b)engineering, design and other creative work activities;(c)intellectual property‑related activities;(d)software development and database activities;(e)marketing and brand equity activities;(f)employee training activities;(g)activities related to the acquisition or lease of tangible assets;(h)innovation management activities.”.

Subject to this section, where a company carrying on a trade or business has made, in the period specified under subsection (2)(b) for that agreement, any payment under an innovation cost‑sharing agreement approved by the Minister or an authorised body on or after 19 February 2025 in respect of one or more qualifying innovation activities carried out under that agreement, there is allowed a deduction of the amount of such payment for the purpose of ascertaining the income of the company.

“benefit”, in relation to an innovation cost‑sharing agreement, means —(a)any right arising from the agreement;(b)any technology, know‑how, intellectual property or software developed from any qualifying innovation activity carried out under the agreement; or(c)any asset acquired under the agreement;

“innovation cost‑sharing agreement” means any agreement or arrangement made by 2 or more related parties to share the expenditure of qualifying innovation activities to be carried out under the agreement or arrangement (and no other expenditure);

“qualifying innovation activity” means an activity falling within any of the following categories of activities, being categories specified in the document entitled “Oslo Manual 2018 — Guidelines for Collecting, Reporting and Using Data on Innovation” that is published by the Organisation for Economic Co‑operation and Development on 22 October 2018:(a)research and experimental development activities;(b)engineering, design and other creative work activities;(c)intellectual property‑related activities;(d)software development and database activities;(e)marketing and brand equity activities;(f)employee training activities;(g)activities related to the acquisition or lease of tangible assets;(h)innovation management activities.”.

The Minister or authorised body may —(a)impose such conditions as the Minister or authorised body thinks fit when approving an innovation cost‑sharing agreement; and(b)specify the period during which any payment made under the innovation cost‑sharing agreement is allowed a deduction under this section.

The Minister or authorised body may approve an innovation cost‑sharing agreement only if —(a)the agreement provides that any benefit arising from the agreement accrues (whether wholly or partly) to the company;(b)there is an undertaking by the company that at least one of the qualifying innovation activities is to be carried out by or on behalf of the company (whether wholly or partly) in Singapore; and(c)such other requirements as the Minister or authorised body specifies, are satisfied.

A deduction is not allowed under subsection (1) if —(a)benefit arising from the approved innovation cost‑sharing agreement (if any) does not accrue (whether wholly or partly) to the company; or(b)no qualifying innovation activity is carried out in Singapore by or on behalf of the company.

No approval under this section may be granted after 31 December 2030.

If any benefit that arose from an approved innovation cost‑sharing agreement during the period specified for it under subsection (2)(b) is sold, assigned or otherwise disposed of at any time by the company to which a deduction has been allowed under subsection (1), the lower of the following is treated as a trading receipt of the company’s trade or business for the year of assessment which relates to the basis period in which the sale, assignment or disposal occurs:(a)the amount of deduction that has been allowed under subsection (1) that is attributable to the benefit, to the extent that this amount of deduction has not been previously treated as a trading receipt under this subsection;(b)the amount or value of the consideration received by the company from the sale, assignment or disposal.

If, for any reason, the deduction cannot be attributed to that benefit, the full amount of the deduction that has been allowed under subsection (1) is treated as being attributable to that benefit.

A sale, assignment or disposal of any benefit that occurs after the date on which the company permanently ceases its trade or business is treated as having occurred immediately before the cessation.

The payment mentioned in subsection (1) does not include any payment to the extent that it is or is to be subsidised by grants or subsidies from the Government or a statutory board.

Where a company to which a deduction has been allowed for any payment made under this section becomes entitled to any royalty or other payments (in one lump sum or otherwise) for the use of or right to use any technology, know‑how or intellectual property developed from a qualifying innovation activity carried out under the approved innovation cost‑sharing agreement, such royalty or payments are treated as income of that company that is derived from Singapore for the year of assessment which relates to the basis period in which that company becomes entitled to the royalty or payments, as the case may be.

Where an innovation cost‑sharing agreement has been approved by the Minister or authorised body for the purposes of this section, then during the period specified under subsection (2)(b) for the agreement —(a)a company is only allowed a deduction under this section in respect of any payment made under the agreement; and(b)no deduction or allowance is allowed under section 14A, 14C, 14D, 14EA, 14U or 19B in respect of such payment despite anything in that section.

For the purposes of this section, any payment made by a company prior to the commencement of that company’s trade or business is treated as having been made by that company on the first day that the company carries on that trade or business, but a deduction for such payment is subject to section 14X.

In this section —(a)a reference to a payment made by a company under an innovation cost‑sharing agreement is a reference to the expenditure that is allocated to the company to bear under the agreement, and the time the payment for any part of the expenditure becomes payable by the company or (if no such payment is needed) the time of the allocation, is treated as the time the payment is made; and(b)a reference to a payment made by a company under an innovation cost‑sharing agreement excludes any payment for the right to be a party to the agreement.

In this section —

—(1) In the ITA, in section 14G —(a)replace the section heading with —“Provisions by banks and qualifying finance companies for impairment losses, etc., from non‑credit‑impaired loans and securities”;(b)in subsection (1), replace “the provision for doubtful debts arising from its loans and the provision for diminution in the value of its investments in securities, made in that basis period” with “provisions made in that basis period by the bank or qualifying finance company for impairment losses or expected credit losses arising from its loans or investments in securities, or both, where the loans or securities are not credit‑impaired (each called in this section provision for losses)”;(c)in subsections (2)(a) and (b) and (2B), replace “provisions” with “provisions for losses”;(d)in subsections (2A) and (2E), replace “provisions for doubtful debts arising from its loans and for the diminution in the value of its investments in securities,” with “provisions for losses”;(e)in subsection (2C)(a)(i) and (ii) and (b)(i) and (ii), replace “provisions made for expected credit losses arising” with “provisions for losses that are made for expected credit losses that arose”;(f)in subsection (2CA)(a) and (b), replace “provision made for expected credit losses of” with “provision for losses that are made for expected credit losses that arose from”;(g)in subsection (4A), replace paragraph (c) with —“(c)a provision for losses made for impairment losses or expected credit losses that arose from those loans or investments in those securities, is also transferred by the transferor to the transferee; and”;(h)in subsection (6A), replace “provision for doubtful debts arising from loans, or for diminution in the value of investments in securities,” with “provision for losses”;(i)in subsection (7), delete the definition of “provisions”; and(j)in subsection (7), replace the definition of “qualifying profit” with —“ “qualifying profit” means the net profit as shown in the audited accounts of the bank or qualifying finance company before deducting —(a)any provision for taxation;(b)any tax paid; and(c)any provision for losses;”.(2) The amendments to section 14G of the ITA apply for the year of assessment 2027 and any subsequent year of assessment.

In the ITA, in section 14G —(a)replace the section heading with —“Provisions by banks and qualifying finance companies for impairment losses, etc., from non‑credit‑impaired loans and securities”;(b)in subsection (1), replace “the provision for doubtful debts arising from its loans and the provision for diminution in the value of its investments in securities, made in that basis period” with “provisions made in that basis period by the bank or qualifying finance company for impairment losses or expected credit losses arising from its loans or investments in securities, or both, where the loans or securities are not credit‑impaired (each called in this section provision for losses)”;(c)in subsections (2)(a) and (b) and (2B), replace “provisions” with “provisions for losses”;(d)in subsections (2A) and (2E), replace “provisions for doubtful debts arising from its loans and for the diminution in the value of its investments in securities,” with “provisions for losses”;(e)in subsection (2C)(a)(i) and (ii) and (b)(i) and (ii), replace “provisions made for expected credit losses arising” with “provisions for losses that are made for expected credit losses that arose”;(f)in subsection (2CA)(a) and (b), replace “provision made for expected credit losses of” with “provision for losses that are made for expected credit losses that arose from”;(g)in subsection (4A), replace paragraph (c) with —“(c)a provision for losses made for impairment losses or expected credit losses that arose from those loans or investments in those securities, is also transferred by the transferor to the transferee; and”;(h)in subsection (6A), replace “provision for doubtful debts arising from loans, or for diminution in the value of investments in securities,” with “provision for losses”;(i)in subsection (7), delete the definition of “provisions”; and(j)in subsection (7), replace the definition of “qualifying profit” with —“ “qualifying profit” means the net profit as shown in the audited accounts of the bank or qualifying finance company before deducting —(a)any provision for taxation;(b)any tax paid; and(c)any provision for losses;”.

The amendments to section 14G of the ITA apply for the year of assessment 2027 and any subsequent year of assessment.

In the ITA, in section 14H(1A)(a)(ii) and (8), replace “2025” with “2030”.

In the ITA, in section 14M —(a)in subsection (1)(a), replace “the year of assessment 2012 or any subsequent year of assessment” with “any year of assessment between the year of assessment 2012 and the year of assessment 2025 (both years inclusive)”;(b)after subsection (2), insert —“(2A) Where —(a)a special purpose vehicle has acquired treasury shares or previously issued shares in a company and, in the basis period for the year of assessment 2026 or any subsequent year of assessment, transfers those shares to any person under a stock option scheme or a share award scheme by reason of any office or employment held in Singapore by that person in the company; and(b)payment by the company for the shares transferred to the person has become due and payable,then the company is allowed a deduction for the relevant year of assessment of an amount referred to in subsection (2B).(2B) The amount of deduction under subsection (2A) is —(a)where the transferred shares are previously issued shares, the lower of the following:(i)the amount paid or payable by the company for the shares, less any amount paid or payable by the person for the shares, to the extent the amount so paid or payable has not been deducted from the firstmentioned amount;(ii)the cost to the special purpose vehicle of acquiring the shares, less any amount paid or payable by the person for the shares; or(b)where the transferred shares are treasury shares, the cost to the company of acquiring the shares, less any amount paid or payable by the person for the shares.”;(c)in subsection (3), replace “subsection (2)(a)(ii) and (b)(i)(B)” with “subsections (2)(a)(ii) and (b)(i)(B) and (2B)(a)(ii)”;(d)in subsection (4)(c), after “subsection (1)”, insert “or (2A) (as the case may be)”;(e)in subsection (4)(c), in the definition of “D”, after “subsection (1)”, insert “or (2A) (as the case may be)”;(f)in subsection (5), replace “subsection (2)(b)(i)(C) and (ii)” with “subsections (2)(b)(i)(C) and (ii) and (2B)(b)”;(g)in subsection (7), replace “the subsidiary company” wherever it appears with “subsidiary X”;(h)in subsection (7)(a), replace “the year of assessment 2012 or any subsequent year of assessment” with “any year of assessment between the year of assessment 2012 and the year of assessment 2025 (both years inclusive)”;(i)in subsection (8)(a)(i) and (b)(i)(A), replace “the subsidiary company” with “subsidiary X”;(j)after subsection (8), insert —“(8A) Where —(a)a special purpose vehicle has acquired treasury shares or previously issued shares in the holding company of another company (called in this section subsidiary Y) and, in the basis period for the year of assessment 2026 or any subsequent year of assessment, transfers those shares to a person under a stock option scheme or a share award scheme by reason of any office or employment held in Singapore by that person in subsidiary Y; and(b)payment by subsidiary Y for the shares transferred to the person has become due and payable,then subsidiary Y is allowed a deduction for the relevant year of assessment of an amount mentioned in subsection (8B).(8B) The amount of deduction under subsection (8A) is —(a)where the transferred shares are previously issued shares, the lower of the following:(i)the amount paid or payable by subsidiary Y for the shares, less any amount paid or payable by the person for the shares, to the extent the amount so paid or payable has not been deducted from the firstmentioned amount;(ii)the cost to the special purpose vehicle of acquiring the shares, less any amount paid or payable by the person for the shares; or(b)where the transferred shares are treasury shares, the lower of the following:(i)the amount paid or payable by subsidiary Y for the shares, less any amount paid or payable by the person for the shares, to the extent the amount so paid or payable has not been deducted from the firstmentioned amount;(ii)the cost to the holding company of acquiring the shares, as determined in accordance with section 14L(8A), less any amount paid or payable by the person for the shares.”;(k)in subsection (9), replace “subsection (8)” with “subsections (8)(a)(ii) and (b)(i)(B) and (8B)(a)(ii)”;(l)in subsection (9), replace “the subsidiary company” with “subsidiary X or subsidiary Y (as the case may be)”;(m)in subsection (10)(a), delete “and” at the end;(n)in subsection (10)(b), replace the full‑stop at the end with “; and”;(o)in subsection (10), after paragraph (b), insert —“(c)a reference to subsection (2A) is a reference to subsection (8A).”;(p)in subsection (13), in the definition of “regular interval”, in paragraph (b)(i), replace “or subsidiary company” with “, subsidiary X or subsidiary Y”;(q)in subsection (13), in the definition of “relevant year of assessment”, in paragraph (a), replace “or (7)” with “, (2A), (7) or (8A)”;(r)in subsection (13), in the definition of “relevant year of assessment”, in paragraphs (a) and (b), replace “or subsidiary company” with “, subsidiary X or subsidiary Y”;(s)in subsection (13), in the definition of “special purpose vehicle”, in paragraph (a), after “subsection (1)”, insert “or (2A)”;(t)in subsection (13), in the definition of “special purpose vehicle”, in paragraph (a)(ii), delete “or” at the end;(u)in subsection (13), in the definition of “special purpose vehicle”, in paragraph (b), replace “subsidiary company referred to in that subsection” with “subsidiary X”;(v)in subsection (13), in the definition of “special purpose vehicle”, in paragraph (b), replace the full‑stop at the end with “; or”; and(w)in subsection (13), in the definition of “special purpose vehicle”, after paragraph (b), insert —“(c)in the case of subsection (8A), shares in one company within a group of companies to which both the holding company and subsidiary Y belong, are to be used for the remuneration of a person by reason of any office or employment held by that person in a company within the same group of companies.”.

“(2A) Where —(a)a special purpose vehicle has acquired treasury shares or previously issued shares in a company and, in the basis period for the year of assessment 2026 or any subsequent year of assessment, transfers those shares to any person under a stock option scheme or a share award scheme by reason of any office or employment held in Singapore by that person in the company; and(b)payment by the company for the shares transferred to the person has become due and payable,then the company is allowed a deduction for the relevant year of assessment of an amount referred to in subsection (2B).

The amount of deduction under subsection (2A) is —(a)where the transferred shares are previously issued shares, the lower of the following:(i)the amount paid or payable by the company for the shares, less any amount paid or payable by the person for the shares, to the extent the amount so paid or payable has not been deducted from the firstmentioned amount;(ii)the cost to the special purpose vehicle of acquiring the shares, less any amount paid or payable by the person for the shares; or(b)where the transferred shares are treasury shares, the cost to the company of acquiring the shares, less any amount paid or payable by the person for the shares.”;

“(8A) Where —(a)a special purpose vehicle has acquired treasury shares or previously issued shares in the holding company of another company (called in this section subsidiary Y) and, in the basis period for the year of assessment 2026 or any subsequent year of assessment, transfers those shares to a person under a stock option scheme or a share award scheme by reason of any office or employment held in Singapore by that person in subsidiary Y; and(b)payment by subsidiary Y for the shares transferred to the person has become due and payable,then subsidiary Y is allowed a deduction for the relevant year of assessment of an amount mentioned in subsection (8B).

The amount of deduction under subsection (8A) is —(a)where the transferred shares are previously issued shares, the lower of the following:(i)the amount paid or payable by subsidiary Y for the shares, less any amount paid or payable by the person for the shares, to the extent the amount so paid or payable has not been deducted from the firstmentioned amount;(ii)the cost to the special purpose vehicle of acquiring the shares, less any amount paid or payable by the person for the shares; or(b)where the transferred shares are treasury shares, the lower of the following:(i)the amount paid or payable by subsidiary Y for the shares, less any amount paid or payable by the person for the shares, to the extent the amount so paid or payable has not been deducted from the firstmentioned amount;(ii)the cost to the holding company of acquiring the shares, as determined in accordance with section 14L(8A), less any amount paid or payable by the person for the shares.”;

In the ITA, after section 14M, insert —“Deduction for new shares issued by holding company under employee equity‑based remuneration scheme14MA.—(1) Where —(a)in the basis period for the year of assessment 2026 or any subsequent year of assessment —(i)a company issues new shares; or (ii)a special purpose vehicle that was issued new shares of a company (whether or not those shares were issued in that basis period) transfers those shares, to a person (called in this section an employee) under a stock option scheme or a share award scheme by reason of any office or employment held in Singapore by that employee in a subsidiary of the company; and(b)payment by the subsidiary for the shares issued or transferred to the employee has become due and payable,then the subsidiary is allowed a deduction of an amount mentioned in subsection (2) in the year of assessment relating to the basis period in which paragraph (a) or (b) occurs, whichever is later.(2) The amount of deduction under subsection (1) is the lower of —(a)the amount paid or payable by the subsidiary for the shares, less any amount paid or payable by the employee for the shares to the extent the secondmentioned amount has not been deducted from the firstmentioned amount; and(b)the value of the shares at the time of issue under subsection (1)(a)(i) or transfer under subsection (1)(a)(ii) (as the case may be) of the shares to the employee, less any amount paid or payable by the employee for the shares.(3) For the purpose of subsection (2)(b), the value of the shares is —(a)the price of the shares in the open market; or (b)if it is not possible to determine that price, the net asset value of the shares at the time of their issue under subsection (1)(a)(i) or transfer under subsection (1)(a)(ii) (as the case may be) to the employee.(4) For the purpose of this section, shares are issued or transferred to an employee when the employee acquires the legal and beneficial interest in the shares.(5) No deduction is allowed to a subsidiary under this section if a deduction has already been allowed to the subsidiary under any other provision of this Act in respect of the shares issued or transferred to the employee.(6) In this section —“group of companies” means 2 or more companies each of which is either a holding company or subsidiary of the other or any of the others;“shares” includes stocks but does not include redeemable or convertible shares or shares of a preferential nature;“special purpose vehicle” means a trustee of a trust (when acting in such capacity) that is set up solely for the administration of a stock option scheme or share award scheme under which shares in one company within a group of companies to which both the company and subsidiary mentioned in subsection (1) belong, are to be used for the remuneration of a person by reason of any office or employment held by that person in a company within that group of companies.”.

Where —(a)in the basis period for the year of assessment 2026 or any subsequent year of assessment —(i)a company issues new shares; or (ii)a special purpose vehicle that was issued new shares of a company (whether or not those shares were issued in that basis period) transfers those shares, to a person (called in this section an employee) under a stock option scheme or a share award scheme by reason of any office or employment held in Singapore by that employee in a subsidiary of the company; and(b)payment by the subsidiary for the shares issued or transferred to the employee has become due and payable,then the subsidiary is allowed a deduction of an amount mentioned in subsection (2) in the year of assessment relating to the basis period in which paragraph (a) or (b) occurs, whichever is later.

“group of companies” means 2 or more companies each of which is either a holding company or subsidiary of the other or any of the others;

“shares” includes stocks but does not include redeemable or convertible shares or shares of a preferential nature;

“special purpose vehicle” means a trustee of a trust (when acting in such capacity) that is set up solely for the administration of a stock option scheme or share award scheme under which shares in one company within a group of companies to which both the company and subsidiary mentioned in subsection (1) belong, are to be used for the remuneration of a person by reason of any office or employment held by that person in a company within that group of companies.”.

The amount of deduction under subsection (1) is the lower of —(a)the amount paid or payable by the subsidiary for the shares, less any amount paid or payable by the employee for the shares to the extent the secondmentioned amount has not been deducted from the firstmentioned amount; and(b)the value of the shares at the time of issue under subsection (1)(a)(i) or transfer under subsection (1)(a)(ii) (as the case may be) of the shares to the employee, less any amount paid or payable by the employee for the shares.

For the purpose of subsection (2)(b), the value of the shares is —(a)the price of the shares in the open market; or (b)if it is not possible to determine that price, the net asset value of the shares at the time of their issue under subsection (1)(a)(i) or transfer under subsection (1)(a)(ii) (as the case may be) to the employee.

For the purpose of this section, shares are issued or transferred to an employee when the employee acquires the legal and beneficial interest in the shares.

No deduction is allowed to a subsidiary under this section if a deduction has already been allowed to the subsidiary under any other provision of this Act in respect of the shares issued or transferred to the employee.

In this section —

In the ITA, in section 14X(2)(c) —(a)after “14EA,”, insert “14EB,”; and(b)after “14EA(8),”, insert “14EB(12),”.

In the ITA, after section 14ZI, insert —“Deduction for expenditure on green certificates and green credits14ZJ.—(1) A person carrying on a trade or business who surrenders any green certificates or green credits prescribed by rules made under section 7 is allowed, for the year of assessment relating to the basis period in which the person surrenders them, a deduction for any qualifying expenditure the person incurred for them during the basis period relating to the year of assessment 2026 or any subsequent year of assessment.(2) Qualifying expenditure, in relation to any green certificates or green credits, means —(a)any expenditure incurred for their acquisition, their registration with the relevant registry, their issue, or their transfer to the person concerned; (b)any expenditure incurred for their surrender; or(c)any expenditure incurred for such other matter as may be prescribed by rules made under section 7.(3) In this section, “surrender”, in relation to any green certificates or green credits, means to surrender or retire the green certificates or green credits, but excludes any activity as may be prescribed by rules made under section 7.”.

Qualifying expenditure, in relation to any green certificates or green credits, means —(a)any expenditure incurred for their acquisition, their registration with the relevant registry, their issue, or their transfer to the person concerned; (b)any expenditure incurred for their surrender; or(c)any expenditure incurred for such other matter as may be prescribed by rules made under section 7.

In this section, “surrender”, in relation to any green certificates or green credits, means to surrender or retire the green certificates or green credits, but excludes any activity as may be prescribed by rules made under section 7.”.

A person carrying on a trade or business who surrenders any green certificates or green credits prescribed by rules made under section 7 is allowed, for the year of assessment relating to the basis period in which the person surrenders them, a deduction for any qualifying expenditure the person incurred for them during the basis period relating to the year of assessment 2026 or any subsequent year of assessment.

—(1) In the ITA, in section 15 —(a)in subsection (1)(i), after sub‑paragraph (ii), insert —“(iia)such payment made on or after 1 January 2026 by an employer on behalf of the employer’s employee directed to be paid to the medisave account of that employee in accordance with section 13B of the Central Provident Fund Act 1953;”;(b)in subsection (1)(i), reletter the existing sub‑paragraphs (iia) and (iib) as sub‑paragraphs (iib) and (iic), respectively;(c)in subsection (1)(p), delete “or” at the end;(d)in subsection (1)(q), after “section 14M(7)”, insert “or (8A) or 14MA(1)”;(e)in subsection (1)(q), replace the full‑stop at the end with “; or”;(f)in subsection (1), after paragraph (q), insert —“(r)any payment made, or any outgoings and expenses incurred, by the person in furtherance of, or in connection with, the commission of an offence under Part 3 of the Prevention of Corruption Act 1960 or section 161, 162, 163, 164, 165, 204B, 213, 214 or 215 of the Penal Code 1871.”;(g)in subsection (2), after “14EA,”, insert “14EB,”;(h)in subsection (2), after “14M,”, insert “14MA,”;(i)in subsection (2A), replace “or 14Z” with “, 14Z or 14ZJ”; and(j)in subsection (2C), after “section 14C(1)(g)”, insert “or 14EB”.(2) The amendments to section 15(1)(i) of the ITA apply for the year of assessment 2027 and any subsequent year of assessment.

In the ITA, in section 15 —(a)in subsection (1)(i), after sub‑paragraph (ii), insert —“(iia)such payment made on or after 1 January 2026 by an employer on behalf of the employer’s employee directed to be paid to the medisave account of that employee in accordance with section 13B of the Central Provident Fund Act 1953;”;(b)in subsection (1)(i), reletter the existing sub‑paragraphs (iia) and (iib) as sub‑paragraphs (iib) and (iic), respectively;(c)in subsection (1)(p), delete “or” at the end;(d)in subsection (1)(q), after “section 14M(7)”, insert “or (8A) or 14MA(1)”;(e)in subsection (1)(q), replace the full‑stop at the end with “; or”;(f)in subsection (1), after paragraph (q), insert —“(r)any payment made, or any outgoings and expenses incurred, by the person in furtherance of, or in connection with, the commission of an offence under Part 3 of the Prevention of Corruption Act 1960 or section 161, 162, 163, 164, 165, 204B, 213, 214 or 215 of the Penal Code 1871.”;(g)in subsection (2), after “14EA,”, insert “14EB,”;(h)in subsection (2), after “14M,”, insert “14MA,”;(i)in subsection (2A), replace “or 14Z” with “, 14Z or 14ZJ”; and(j)in subsection (2C), after “section 14C(1)(g)”, insert “or 14EB”.

The amendments to section 15(1)(i) of the ITA apply for the year of assessment 2027 and any subsequent year of assessment.

In the ITA, in section 18C —(a)in subsection (1B), replace “2025” with “2030”; and(b)in subsection (15)(b), replace sub‑paragraphs (i) to (v) with —“(i)where the application for planning permission or conservation permission is made between 25 March 2016 and 31 December 2025 (both dates inclusive) and the application under subsection (1) or (1A) is made on or after 25 March 2016 —(A)one of those persons beneficially holds, directly or indirectly, at least 75% of the total number of issued ordinary shares of the other person (being a company);(B)one of those persons is entitled, directly or indirectly, to at least 75% of the income of the other person (being a partnership);(C)a third person beneficially holds, directly or indirectly, at least 75% of the total number of issued ordinary shares of each of those persons (being companies);(D)a third person is entitled, directly or indirectly, to at least 75% of the income of each of those persons (being partnerships); or(E)a third person beneficially holds, directly or indirectly, at least 75% of the total number of issued ordinary shares of one of those persons (being a company), and is entitled, directly or indirectly, to at least 75% of the income of the other person (being a partnership); or(ii)where the application for planning permission or conservation permission and the application under subsection (1) or (1A) are made on or after 1 January 2026 —(A)one of those persons beneficially holds, directly or indirectly, more than 50% of the total number of issued ordinary shares of the other person (being a company);(B)one of those persons is entitled, directly or indirectly, to more than 50% of the income of the other person (being a partnership);(C)a third person beneficially holds, directly or indirectly, more than 50% of the total number of issued ordinary shares of each of those persons (being companies);(D)a third person is entitled, directly or indirectly, to more than 50% of the income of each of those persons (being partnerships); or(E)a third person beneficially holds, directly or indirectly, more than 50% of the total number of issued ordinary shares of one of those persons (being a company), and is entitled, directly or indirectly, to more than 50% of the income of the other person (being a partnership).”.

In the ITA, in section 19B(10A)(a)(i), after “14EA”, insert “, 14EB”.

—(1) In the ITA, in section 34AA —(a)in subsection (3), replace paragraph (h) with —“(h)despite paragraph (g), section 14G applies in relation to a provision made by a qualifying person that is a bank or qualifying finance company for an expected credit loss arising from its loans or investments in securities, or both, where the loans or securities are not credit impaired;”; and(b)in subsection (15), after the definition of “debt securities”, insert —“ “expected credit loss” has the meaning given by FRS 109 or SFRS(I) 9;”.(2) The amendments to section 34AA(3) and (15) of the ITA apply for the year of assessment 2027 and any subsequent year of assessment.

In the ITA, in section 34AA —(a)in subsection (3), replace paragraph (h) with —“(h)despite paragraph (g), section 14G applies in relation to a provision made by a qualifying person that is a bank or qualifying finance company for an expected credit loss arising from its loans or investments in securities, or both, where the loans or securities are not credit impaired;”; and(b)in subsection (15), after the definition of “debt securities”, insert —“ “expected credit loss” has the meaning given by FRS 109 or SFRS(I) 9;”.

The amendments to section 34AA(3) and (15) of the ITA apply for the year of assessment 2027 and any subsequent year of assessment.

In the ITA, in section 34CA —(a)in subsection (1)(c), after “after date A”, insert “(or such other period as may be allowed under subsection (1A))”;(b)after subsection (1), insert —“(1A) The Minister or Comptroller may, in a particular case, extend the period of 12 months before or after date A that date B must fall.”; and(c)in subsection (3)(d), after “prescribed date”, insert “or such later date as the Minister or Comptroller may allow in a particular case”.

“(1A) The Minister or Comptroller may, in a particular case, extend the period of 12 months before or after date A that date B must fall.”; and

In the ITA, in section 34D, after subsection (2A), insert —“Transactions with partnerships(3) In subsections (1)(a) and (b), (1B), (1C) and (2) —(a)a reference to a person includes a partnership; and(b)a person (X) is treated as a related party of another person (Y) that is a partnership if X is related to Y in such manner as may be prescribed by rules made under section 7.(4) In a case where a related party is a partnership, a reference to the person in subsections (1)(c) and (1A) is to a partner of the partnership.Transactions involving trusts(5) In subsections (1)(a) and (b), (1B), (1C) and (2) —(a)a reference to a person includes the trustee of a trust (excluding a registered business trust) when acting in that capacity; and(b)a person (X1) is treated as a related party of another person (Y1) that is a trustee of a trust (excluding a registered business trust) if X1 is related to Y1 in such manner as may be prescribed by rules made under section 7.(6) In a case where a related party is the trustee of a trust (excluding a registered business trust), a reference to the person in subsections (1)(c) and (1A) is to the person in whose hands the income, deduction or loss concerned is taxable or deductible under this Act.(7) In subsections (1)(a) and (2) —(a)a reference to a person includes a registered business trust; and(b)a person (X2) is treated as a related party of another person (Y2) that is a registered business trust, if X2 is related to Y2 in such manner as may be prescribed by rules made under section 7.(8) In a case where a related party is a registered business trust (Y2) —(a)a reference in subsections (1)(b), (1B) and (1C) to commercial or financial relations Y2 has with another party, is to commercial or financial relations entered into by its trustee‑manager (Z) (for or on behalf of Y2) with the other party, and a reference in those provisions to conditions made or imposed in those commercial or financial relations is to conditions made or imposed between Z (for or on behalf of Y2) and the other party; (b)a reference to the person in subsections (1)(c) and (1A) is to the registered business trust; and(c)a reference to the carrying on of business by a person in subsection (2) that is Y2 is to the trustee‑manager carrying on business for or on behalf of Y2.(9) This section does not apply where the related parties are parties to a trust mentioned in subsection (10), and the transaction in question is for the carrying out of the trust.(10) Subsection (9) applies to a trust of which —(a)every settlor is an individual; and(b)every beneficiary is an individual or a charitable institution, trust or body of persons established for a philanthropic purpose only,and that is not one of the following:(c)a real estate investment trust within the meaning of section 43(10);(d)a unit trust within the meaning of section 10A;(e)a business trust within the meaning of section 2 of the Business Trusts Act 2004; (f)any other trust that is established for the purpose of carrying out a business or commercial activity.(11) In this section —“philanthropic purpose” means any purpose mentioned in paragraphs (a) to (k) of the definition of “philanthropic purpose trust” in section 13L(3);“registered business trust” has the meaning given by section 2 of the Business Trusts Act 2004.”.

In subsections (1)(a) and (b), (1B), (1C) and (2) —(a)a reference to a person includes a partnership; and(b)a person (X) is treated as a related party of another person (Y) that is a partnership if X is related to Y in such manner as may be prescribed by rules made under section 7.

In a case where a related party is a partnership, a reference to the person in subsections (1)(c) and (1A) is to a partner of the partnership.

In subsections (1)(a) and (b), (1B), (1C) and (2) —(a)a reference to a person includes the trustee of a trust (excluding a registered business trust) when acting in that capacity; and(b)a person (X1) is treated as a related party of another person (Y1) that is a trustee of a trust (excluding a registered business trust) if X1 is related to Y1 in such manner as may be prescribed by rules made under section 7.

In a case where a related party is the trustee of a trust (excluding a registered business trust), a reference to the person in subsections (1)(c) and (1A) is to the person in whose hands the income, deduction or loss concerned is taxable or deductible under this Act.

In subsections (1)(a) and (2) —(a)a reference to a person includes a registered business trust; and(b)a person (X2) is treated as a related party of another person (Y2) that is a registered business trust, if X2 is related to Y2 in such manner as may be prescribed by rules made under section 7.

In a case where a related party is a registered business trust (Y2) —(a)a reference in subsections (1)(b), (1B) and (1C) to commercial or financial relations Y2 has with another party, is to commercial or financial relations entered into by its trustee‑manager (Z) (for or on behalf of Y2) with the other party, and a reference in those provisions to conditions made or imposed in those commercial or financial relations is to conditions made or imposed between Z (for or on behalf of Y2) and the other party; (b)a reference to the person in subsections (1)(c) and (1A) is to the registered business trust; and(c)a reference to the carrying on of business by a person in subsection (2) that is Y2 is to the trustee‑manager carrying on business for or on behalf of Y2.

This section does not apply where the related parties are parties to a trust mentioned in subsection (10), and the transaction in question is for the carrying out of the trust.

Subsection (9) applies to a trust of which —(a)every settlor is an individual; and(b)every beneficiary is an individual or a charitable institution, trust or body of persons established for a philanthropic purpose only,and that is not one of the following:(c)a real estate investment trust within the meaning of section 43(10);(d)a unit trust within the meaning of section 10A;(e)a business trust within the meaning of section 2 of the Business Trusts Act 2004; (f)any other trust that is established for the purpose of carrying out a business or commercial activity.

In this section —

“philanthropic purpose” means any purpose mentioned in paragraphs (a) to (k) of the definition of “philanthropic purpose trust” in section 13L(3);

“registered business trust” has the meaning given by section 2 of the Business Trusts Act 2004.”.

In the ITA, in section 34F, after subsection (10), insert —“(11) For the purposes of this section, a related party of a partnership, a trustee of a trust, or a registered business trust is determined by reference to section 34D(3), (5) or (7), as the case may be.(12) Subsection (3) does not apply to a transaction between parties to a trust mentioned in section 34D(10).(13) To avoid doubt, a reference to a company in this section includes (by reason of section 36B(1)) a “registered business trust” as defined by section 2 of the Business Trusts Act 2004.”.

“(11) For the purposes of this section, a related party of a partnership, a trustee of a trust, or a registered business trust is determined by reference to section 34D(3), (5) or (7), as the case may be.

Subsection (3) does not apply to a transaction between parties to a trust mentioned in section 34D(10).

To avoid doubt, a reference to a company in this section includes (by reason of section 36B(1)) a “registered business trust” as defined by section 2 of the Business Trusts Act 2004.”.

In the ITA, in section 36B(1) —(a)replace paragraph (d) with —“(d)for the purposes of section 13W(1) and (1A), any reference in those provisions to ordinary shares or preference shares in investee companies B and B1 (each called an investee company) which are legally and beneficially owned by divesting companies A and A1 (each called a divesting company) respectively, is, in a case where the divesting company is a registered business trust, a reference to ordinary shares or preference shares in the investee company which are trust property of the registered business trust;(da)section 13W(1B) does not apply to a registered business trust;”;(b)in paragraph (e), replace “section 92J” with “sections 92J and 92L”;(c)in paragraph (e), replace “section 92J(7)” with “sections 92J(7) and 92L(7)”; (d)in paragraph (e), in the definition of “local employee”, in paragraph (b), after “2023”, insert “(for the purposes of section 92J) or 2024 (for the purposes of section 92L)”;(e)in paragraph (e), replace the full‑stop at the end with a semi‑colon; and(f)after paragraph (e), insert —“(f)for the purposes of section 92K —(i)any reference to the ordinary shares of a company is a reference to the units in a registered business trust; and(ii)any reference to a subsidiary wholly‑owned (directly or indirectly) by a company is to a company all the shares of which are held (directly or indirectly) for a registered business trust by its trustee‑manager.”.

In the ITA, in section 37O, in the following provisions, replace “2025” with “2030”: Subsection (1) Subsection (1A)(b) Subsection (4A)(a), (b) and (c).

In the ITA, in section 37Q(2)(a), after “14EA(10),”, insert “14EB(9),”.

In the ITA, in section 37R, after subsection (31), insert —“(31A) Where an amount of cash payout is to be made by the Comptroller to an eligible person under this section, and an amount is recoverable by the Comptroller from the eligible person as a debt due to the Government under subsection (20), (21), (22) or (30) —(a)the amount of cash payout to be made by the Comptroller to the eligible person is reduced by the amount so due under that subsection; and(b)the amount of the reduction is treated as a repayment of the debt by the eligible person.(31B) Where the amount of cash payout to be made to an eligible person under this section is less than the sum of the amount of tax, duty, interest or penalty due from the eligible person under subsection (28) and the amount recoverable as a debt due to the Government under subsection (20), (21), (22) or (30), the Comptroller may determine the amount of reduction to be made under subsection (28)(a) or (31A)(a), or both, in a manner that he or she considers reasonable.”.

“(31A) Where an amount of cash payout is to be made by the Comptroller to an eligible person under this section, and an amount is recoverable by the Comptroller from the eligible person as a debt due to the Government under subsection (20), (21), (22) or (30) —(a)the amount of cash payout to be made by the Comptroller to the eligible person is reduced by the amount so due under that subsection; and(b)the amount of the reduction is treated as a repayment of the debt by the eligible person.

Where the amount of cash payout to be made to an eligible person under this section is less than the sum of the amount of tax, duty, interest or penalty due from the eligible person under subsection (28) and the amount recoverable as a debt due to the Government under subsection (20), (21), (22) or (30), the Comptroller may determine the amount of reduction to be made under subsection (28)(a) or (31A)(a), or both, in a manner that he or she considers reasonable.”.

—(1) In the ITA, in section 39 —(a)in subsection (2)(c), replace “a wife from whom he” with “a spouse from whom the individual”;(b)in subsection (2)(d)(v), replace “(being his wife) from whom he” with “from whom the individual”;(c)in subsection (2)(ga)(i), replace “the individual’s life or, in the case of a male individual, on the life of the individual’s wife” with “the life of the individual or the individual’s spouse”;(d)in subsection (2), replace paragraph (ha) with —“(ha)has carried on a trade, business, profession or vocation and has made voluntary contributions to the Central Provident Fund then, subject to subsection (10B), there is to be allowed for the year of assessment 2026 or a subsequent year of assessment a deduction in respect of such contributions of an amount to be determined by the formula A – B, where —(i)A is the lower of —(A)37%, or such other rate as may be prescribed, of the amount of his or her income derived in the basis period for that year of assessment from his or her trade, business, profession or vocation on which contributions were obligatory under the Central Provident Fund Act 1953 (excluding any income on which contributions are obligatory as a Group A worker); and(B)$37,740, or such other amount as may be prescribed; and(ii)B is the amount of any deduction allowed under paragraph (haa),except that if A – B is less than or equal to zero, the amount of deduction is treated as zero;(haa)has made obligatory contributions under the Central Provident Fund Act 1953 in respect of income derived in any year from a trade, business, profession or vocation to the Central Provident Fund then, subject to subsection (10B), there is to be allowed for the year of assessment (being the year of assessment 2026 or a subsequent year of assessment) a deduction in respect of such contributions (excluding obligatory contributions on his or her income derived as a Group A worker);”;(e)in subsection (2)(hb), replace “sub‑paragraphs (ga) and (ha)” with “paragraphs (ga), (ha) and (haa)”;(f)in subsection (2)(hb), replace “sub‑paragraph (ha)” with “paragraph (ha)”;(g)in subsection (3)(c)(ii), after “medisave contributions”, insert “(after deducting the prescribed amount of any MMSS grant, or the total of the prescribed amounts of any MMSS grant, given or to be given in connection with that payment or those payments if the payment or payments was or were made on or after 1 January 2026)”;(h)in subsection (3A)(b), replace “section 39(2)(h)” with “subsection (2)(h) for the year of assessment 2025 or any preceding year of assessment, or under subsection (2)(ha) for the year of assessment 2026 or any subsequent year of assessment”;(i)in subsection (3A)(c)(ii), after “medisave self‑contributions”, insert “(after deducting the prescribed amount of any MMSS grant, or the total of the prescribed amounts of any MMSS grant, given or to be given in connection with that payment or those payments if the payment or payments was or were made on or after 1 January 2026)”;(j)replace subsection (3C) with —“(3C) In subsections (3) and (3A) —“prescribed amount of any MMSS grant” means —(a)the full amount of a grant under the public scheme known as the Matched MediSave Scheme, as described on the website https://cpf.gov.sg; or(b)if an amount of such grant is prescribed by rules made under section 7 for the purposes of this subsection — that amount;“prescribed amount of any MRSS grant” means —(a)the full amount of a grant under the public scheme known as the Matched Retirement Savings Scheme, as described on the website https://cpf.gov.sg; or(b)if an amount of such grant is prescribed by rules made under section 7 for the purposes of this subsection — that amount.”;(k)in subsection (10B), replace “and (ha)” wherever it appears with “, (ha) and (haa)”;(l)in subsection (10B)(d), replace “subsection (2)(ha) (in respect of contributions which are obligatory under the Central Provident Fund Act 1953)” with “subsection (2)(haa)”;(m)in subsection (10B)(d), replace “paragraphs (b) and (c) do” with “paragraph (b) does”; and(n)in subsection (10B)(d), replace “, allowable under subsection (2)(ha)” with “, allowable under subsection (2)(haa)”.(2) The amendments to section 39(2), (3A)(b) and (10B) of the ITA apply for the year of assessment 2026 and any subsequent year of assessment.(3) The amendments to section 39(3)(c) and (3A)(c) and (3C) of the ITA apply for the year of assessment 2027 and any subsequent year of assessment.

In the ITA, in section 39 —(a)in subsection (2)(c), replace “a wife from whom he” with “a spouse from whom the individual”;(b)in subsection (2)(d)(v), replace “(being his wife) from whom he” with “from whom the individual”;(c)in subsection (2)(ga)(i), replace “the individual’s life or, in the case of a male individual, on the life of the individual’s wife” with “the life of the individual or the individual’s spouse”;(d)in subsection (2), replace paragraph (ha) with —“(ha)has carried on a trade, business, profession or vocation and has made voluntary contributions to the Central Provident Fund then, subject to subsection (10B), there is to be allowed for the year of assessment 2026 or a subsequent year of assessment a deduction in respect of such contributions of an amount to be determined by the formula A – B, where —(i)A is the lower of —(A)37%, or such other rate as may be prescribed, of the amount of his or her income derived in the basis period for that year of assessment from his or her trade, business, profession or vocation on which contributions were obligatory under the Central Provident Fund Act 1953 (excluding any income on which contributions are obligatory as a Group A worker); and(B)$37,740, or such other amount as may be prescribed; and(ii)B is the amount of any deduction allowed under paragraph (haa),except that if A – B is less than or equal to zero, the amount of deduction is treated as zero;(haa)has made obligatory contributions under the Central Provident Fund Act 1953 in respect of income derived in any year from a trade, business, profession or vocation to the Central Provident Fund then, subject to subsection (10B), there is to be allowed for the year of assessment (being the year of assessment 2026 or a subsequent year of assessment) a deduction in respect of such contributions (excluding obligatory contributions on his or her income derived as a Group A worker);”;(e)in subsection (2)(hb), replace “sub‑paragraphs (ga) and (ha)” with “paragraphs (ga), (ha) and (haa)”;(f)in subsection (2)(hb), replace “sub‑paragraph (ha)” with “paragraph (ha)”;(g)in subsection (3)(c)(ii), after “medisave contributions”, insert “(after deducting the prescribed amount of any MMSS grant, or the total of the prescribed amounts of any MMSS grant, given or to be given in connection with that payment or those payments if the payment or payments was or were made on or after 1 January 2026)”;(h)in subsection (3A)(b), replace “section 39(2)(h)” with “subsection (2)(h) for the year of assessment 2025 or any preceding year of assessment, or under subsection (2)(ha) for the year of assessment 2026 or any subsequent year of assessment”;(i)in subsection (3A)(c)(ii), after “medisave self‑contributions”, insert “(after deducting the prescribed amount of any MMSS grant, or the total of the prescribed amounts of any MMSS grant, given or to be given in connection with that payment or those payments if the payment or payments was or were made on or after 1 January 2026)”;(j)replace subsection (3C) with —“(3C) In subsections (3) and (3A) —(k)in subsection (10B), replace “and (ha)” wherever it appears with “, (ha) and (haa)”;(l)in subsection (10B)(d), replace “subsection (2)(ha) (in respect of contributions which are obligatory under the Central Provident Fund Act 1953)” with “subsection (2)(haa)”;(m)in subsection (10B)(d), replace “paragraphs (b) and (c) do” with “paragraph (b) does”; and(n)in subsection (10B)(d), replace “, allowable under subsection (2)(ha)” with “, allowable under subsection (2)(haa)”.

“prescribed amount of any MMSS grant” means —(a)the full amount of a grant under the public scheme known as the Matched MediSave Scheme, as described on the website https://cpf.gov.sg; or(b)if an amount of such grant is prescribed by rules made under section 7 for the purposes of this subsection — that amount;

“prescribed amount of any MRSS grant” means —(a)the full amount of a grant under the public scheme known as the Matched Retirement Savings Scheme, as described on the website https://cpf.gov.sg; or(b)if an amount of such grant is prescribed by rules made under section 7 for the purposes of this subsection — that amount.”;

“(3C) In subsections (3) and (3A) —

The amendments to section 39(2), (3A)(b) and (10B) of the ITA apply for the year of assessment 2026 and any subsequent year of assessment.

The amendments to section 39(3)(c) and (3A)(c) and (3C) of the ITA apply for the year of assessment 2027 and any subsequent year of assessment.

In the ITA, in section 43 —(a)in subsection (2A)(a)(i) and (b)(i), replace “or income from the management or holding of immovable property” with “, income from the management or holding of immovable property, co‑location income or co‑working space income,”;(b)in subsection (2A)(a)(ii) and (b)(ii), after “holding of immovable property”, insert “, or that is ancillary to co‑location income or co‑working space income,”;(c)in subsection (2A)(a)(iii), after “immovable property in Singapore,”, insert “or co‑location income or co‑working space income in relation to immovable property in Singapore,”;(d)in subsection (2A)(ba), replace “in the period between 1 July 2018 and 31 December 2025 (both dates inclusive)” with “on or after 1 July 2018”;(e)after subsection (2C), insert —“(2D) In subsection (2A)(a) and (b), any reference to co‑location income or co‑working space income is to such income that is derived on or after 1 July 2025.”;(f)in the following provisions, replace “2025” with “2030”:Subsection (3B)Subsection (3C)(b)Subsection (3D)Subsection (3E);(g)in subsection (3F), after paragraph (a), insert —“(aa)a partner of an approved limited partnership under section 13OA;”;(h)in subsection (3F)(w), replace “or an approved foreign government‑owned entity under section 13V.” with “, an approved foreign government‑owned entity, a prescribed international organisation or an approved international organisation under section 13V.”;(i)in subsection (10), after the definition of “captive insurer”, insert —“ “co‑location income” means any income that is derived from the undertaking of both of the following:(a)the provision of a physical space relating to any immovable property for use by one or more persons to house or operate any information technology equipment belonging to that person or those persons;(b)the provision of any infrastructure, facilities or services, relating to the immovable property used to house or operate the information technology equipment;“co‑working space income” means any income that is derived from the undertaking of both of the following:(a)the provision of a physical space within any immovable property for use by one or more persons to carry out any activity relating to their respective trades, businesses or operations, and to use the communal facilities, within the physical space;(b)the provision of any infrastructure, facilities or services within the immovable property for use by that person or those persons for the purposes mentioned in paragraph (a);”; and(j)after subsection (10), insert —“(10A) In the definition of “co‑location income” in subsection (10), a reference to an immovable property includes such property (whether or not immovable property) used or to be used to house or operate any information technology equipment as may be prescribed by rules made under section 7.”.

“(2D) In subsection (2A)(a) and (b), any reference to co‑location income or co‑working space income is to such income that is derived on or after 1 July 2025.”;

“(10A) In the definition of “co‑location income” in subsection (10), a reference to an immovable property includes such property (whether or not immovable property) used or to be used to house or operate any information technology equipment as may be prescribed by rules made under section 7.”.

In the ITA, in section 43C —(a)in subsection (1), replace paragraph (aa) with —“(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 rateApproved insurer10%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”;(b)in subsection (1)(c), in the table, under the heading “Approved insurer”, in paragraph (ii), replace “on or after 1 April 2018” with “between 1 April 2018 and 18 February 2025 (both dates inclusive)”;(c)in subsection (1)(c), in the table, after the item relating to “10%”, insert — “10% or 15% An approved captive insurer whose approval is granted on or after 19 February 2025”; and(d)after subsection (2), insert —“(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.”.

“(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.”.

—(1) In the ITA, in section 43J —(a)replace subsection (1) with —“(1) Despite section 43, the Minister may by regulations —(a)provide that tax at the rate of 5%, 10%, 12% or 13.5% is to be levied and paid for each year of assessment upon any income specified by the Minister that is derived on or after 1 January 2004 by a financial sector incentive company from one or more prescribed qualifying activities; and(b)provide that tax at the rate of 15% is to be levied and paid for each year of assessment upon any income specified by the Minister that is derived on or after 1 January 2025 by a financial sector incentive company that is approved on or after 19 February 2025 from one or more prescribed qualifying activities.(1A) Regulations made under subsection (1) may provide for the deduction of losses otherwise than in accordance with section 37(3).”;(b)after subsection (2), insert —“(2AA) Regulations made for the purposes of this section may provide the last date by which approval for a financial sector incentive company or a specified class of financial sector incentive companies may be given or extended.”; and(c)after subsection (2A), insert —“(3) Regulations made for the purposes of subsection (1)(b) may be made to take effect from (and including) 1 January 2025.”.(2) In the ITA, in section 43J (as amended by subsection (1)) —(a)in subsection (1)(a), delete “and” at the end;(b)in subsection (1)(b), replace the full‑stop at the end with “; and”;(c)in subsection (1), after paragraph (b), insert —“(c)provide for exemption from tax for each year of assessment of any income specified by the Minister that is derived on or after 19 February 2025 by a financial sector incentive company from one or more prescribed qualifying activities, if the requirements specified by the Minister or an authorised body for the exemption to apply to that income for that year of assessment are satisfied.”;(d)after subsection (1A), insert —“(1B) Despite section 43, the Minister may by regulations provide that tax at the rate of 5% is to be levied and paid for each year of assessment upon any income specified by the Minister that is derived on or after 19 February 2025 by a financial sector incentive company approved under subsection (1C), from one or more prescribed qualifying activities, if the requirements specified by the Minister or an authorised body for the tax rate to apply to that income for that year of assessment are satisfied.(1C) The Minister or an authorised body may approve a company (X) as a financial sector incentive company for the purposes of subsection (1B) only if the following conditions are satisfied:(a)X or its holding company becomes listed on a stock exchange in Singapore on or after 19 February 2025;(b)X or its holding company (as the case may be) is not an approved company under section 92K(6), or an approved nominee under section 92K(15)(a), (16) or (22).(1D) It is a condition of the approval for X that X or its holding company (as the case may be) remains listed on the stock exchange in Singapore throughout the period of X’s approval.(1E) In a case where it is a condition of the approval for X that its holding company remains listed on the stock exchange in Singapore throughout the period of X’s approval, a delisting of the holding company from that stock exchange during that period is treated as a failure by X to comply with a condition of X’s approval under section 105R(1)(b).(1F) Regulations made under subsection (1B) may provide for the deduction of losses otherwise than in accordance with section 37(3).”; and(e)after subsection (3), insert —“(4) Regulations made for the purposes of subsections (1)(c) and (1B) may be made to take effect from (and including) 19 February 2025.(5) The Minister or authorised body may at the time of approving a company as a financial sector incentive company for the purposes of subsection (1)(c), provide in the letter of approval that if a specified requirement is not satisfied by the company on any day in a basis period or throughout a basis period, the tax exemption does not apply to the company’s income for the year of assessment to which the basis period relates or for that year of assessment and subsequent years of assessment.(6) The Minister or authorised body may at the time of approving a company as a financial sector incentive company for the purposes of subsection (1B), provide in the letter of approval that if a specified requirement is not satisfied by the company or its holding company (as the case may be) on any day in a basis period or throughout a basis period, the tax rate of 5% does not apply to the company’s income for the year of assessment to which the basis period relates or for that year of assessment and subsequent years of assessment.(7) In this section, a reference to the holding company of a company (A) is to a company that owns (directly or indirectly) the percentage of ownership in A prescribed in regulations made under subsection (1B).”.

“(1) Despite section 43, the Minister may by regulations —(a)provide that tax at the rate of 5%, 10%, 12% or 13.5% is to be levied and paid for each year of assessment upon any income specified by the Minister that is derived on or after 1 January 2004 by a financial sector incentive company from one or more prescribed qualifying activities; and(b)provide that tax at the rate of 15% is to be levied and paid for each year of assessment upon any income specified by the Minister that is derived on or after 1 January 2025 by a financial sector incentive company that is approved on or after 19 February 2025 from one or more prescribed qualifying activities.

Regulations made under subsection (1) may provide for the deduction of losses otherwise than in accordance with section 37(3).”;

“(2AA) Regulations made for the purposes of this section may provide the last date by which approval for a financial sector incentive company or a specified class of financial sector incentive companies may be given or extended.”; and

“(3) Regulations made for the purposes of subsection (1)(b) may be made to take effect from (and including) 1 January 2025.”.

In the ITA, in section 43J (as amended by subsection (1)) —(a)in subsection (1)(a), delete “and” at the end;(b)in subsection (1)(b), replace the full‑stop at the end with “; and”;(c)in subsection (1), after paragraph (b), insert —“(c)provide for exemption from tax for each year of assessment of any income specified by the Minister that is derived on or after 19 February 2025 by a financial sector incentive company from one or more prescribed qualifying activities, if the requirements specified by the Minister or an authorised body for the exemption to apply to that income for that year of assessment are satisfied.”;(d)after subsection (1A), insert —“(1B) Despite section 43, the Minister may by regulations provide that tax at the rate of 5% is to be levied and paid for each year of assessment upon any income specified by the Minister that is derived on or after 19 February 2025 by a financial sector incentive company approved under subsection (1C), from one or more prescribed qualifying activities, if the requirements specified by the Minister or an authorised body for the tax rate to apply to that income for that year of assessment are satisfied.(1C) The Minister or an authorised body may approve a company (X) as a financial sector incentive company for the purposes of subsection (1B) only if the following conditions are satisfied:(a)X or its holding company becomes listed on a stock exchange in Singapore on or after 19 February 2025;(b)X or its holding company (as the case may be) is not an approved company under section 92K(6), or an approved nominee under section 92K(15)(a), (16) or (22).(1D) It is a condition of the approval for X that X or its holding company (as the case may be) remains listed on the stock exchange in Singapore throughout the period of X’s approval.(1E) In a case where it is a condition of the approval for X that its holding company remains listed on the stock exchange in Singapore throughout the period of X’s approval, a delisting of the holding company from that stock exchange during that period is treated as a failure by X to comply with a condition of X’s approval under section 105R(1)(b).(1F) Regulations made under subsection (1B) may provide for the deduction of losses otherwise than in accordance with section 37(3).”; and(e)after subsection (3), insert —“(4) Regulations made for the purposes of subsections (1)(c) and (1B) may be made to take effect from (and including) 19 February 2025.(5) The Minister or authorised body may at the time of approving a company as a financial sector incentive company for the purposes of subsection (1)(c), provide in the letter of approval that if a specified requirement is not satisfied by the company on any day in a basis period or throughout a basis period, the tax exemption does not apply to the company’s income for the year of assessment to which the basis period relates or for that year of assessment and subsequent years of assessment.(6) The Minister or authorised body may at the time of approving a company as a financial sector incentive company for the purposes of subsection (1B), provide in the letter of approval that if a specified requirement is not satisfied by the company or its holding company (as the case may be) on any day in a basis period or throughout a basis period, the tax rate of 5% does not apply to the company’s income for the year of assessment to which the basis period relates or for that year of assessment and subsequent years of assessment.(7) In this section, a reference to the holding company of a company (A) is to a company that owns (directly or indirectly) the percentage of ownership in A prescribed in regulations made under subsection (1B).”.

“(1B) Despite section 43, the Minister may by regulations provide that tax at the rate of 5% is to be levied and paid for each year of assessment upon any income specified by the Minister that is derived on or after 19 February 2025 by a financial sector incentive company approved under subsection (1C), from one or more prescribed qualifying activities, if the requirements specified by the Minister or an authorised body for the tax rate to apply to that income for that year of assessment are satisfied.

The Minister or an authorised body may approve a company (X) as a financial sector incentive company for the purposes of subsection (1B) only if the following conditions are satisfied:(a)X or its holding company becomes listed on a stock exchange in Singapore on or after 19 February 2025;(b)X or its holding company (as the case may be) is not an approved company under section 92K(6), or an approved nominee under section 92K(15)(a), (16) or (22).

It is a condition of the approval for X that X or its holding company (as the case may be) remains listed on the stock exchange in Singapore throughout the period of X’s approval.

In a case where it is a condition of the approval for X that its holding company remains listed on the stock exchange in Singapore throughout the period of X’s approval, a delisting of the holding company from that stock exchange during that period is treated as a failure by X to comply with a condition of X’s approval under section 105R(1)(b).

Regulations made under subsection (1B) may provide for the deduction of losses otherwise than in accordance with section 37(3).”; and

“(4) Regulations made for the purposes of subsections (1)(c) and (1B) may be made to take effect from (and including) 19 February 2025.

The Minister or authorised body may at the time of approving a company as a financial sector incentive company for the purposes of subsection (1)(c), provide in the letter of approval that if a specified requirement is not satisfied by the company on any day in a basis period or throughout a basis period, the tax exemption does not apply to the company’s income for the year of assessment to which the basis period relates or for that year of assessment and subsequent years of assessment.

The Minister or authorised body may at the time of approving a company as a financial sector incentive company for the purposes of subsection (1B), provide in the letter of approval that if a specified requirement is not satisfied by the company or its holding company (as the case may be) on any day in a basis period or throughout a basis period, the tax rate of 5% does not apply to the company’s income for the year of assessment to which the basis period relates or for that year of assessment and subsequent years of assessment.

In this section, a reference to the holding company of a company (A) is to a company that owns (directly or indirectly) the percentage of ownership in A prescribed in regulations made under subsection (1B).”.

In the ITA, in section 43J —(a)replace subsection (1) with —“(1) Despite section 43, the Minister may by regulations —(a)provide that tax at the rate of 5%, 10%, 12% or 13.5% is to be levied and paid for each year of assessment upon any income specified by the Minister that is derived on or after 1 January 2004 by a financial sector incentive company from one or more prescribed qualifying activities; and(b)provide that tax at the rate of 15% is to be levied and paid for each year of assessment upon any income specified by the Minister that is derived on or after 1 January 2025 by a financial sector incentive company that is approved on or after 19 February 2025 from one or more prescribed qualifying activities.(1A) Regulations made under subsection (1) may provide for the deduction of losses otherwise than in accordance with section 37(3).”;(b)after subsection (2), insert —“(2AA) Regulations made for the purposes of this section may provide the last date by which approval for a financial sector incentive company or a specified class of financial sector incentive companies may be given or extended.”; and(c)after subsection (2A), insert —“(3) Regulations made for the purposes of subsection (1)(b) may be made to take effect from (and including) 1 January 2025.”.

In the ITA, in section 43L(4A), replace “2026” with “2031”.

In the ITA, in section 43P —(a)replace subsection (2C) with —“(2C) Subsection (1)(a), (c), (e) and (f) does not apply to —(a)income derived between 12 December 2018 and 18 February 2025 (both dates inclusive) from the leasing of a container or intermodal equipment that is acquired by the approved container investment enterprise or the approved related party by way of a finance lease entered into with an entity that is not an approved related party; or(b)income derived on or after 19 February 2025 from the leasing of a container or intermodal equipment that is acquired by the approved container investment enterprise or the approved related party by way of a finance lease not treated as a sale under section 10C, entered into with an entity that is not an approved related party.”; and(b)in subsections (3) and (4)(b), replace “2026” with “2031”.

“(2C) Subsection (1)(a), (c), (e) and (f) does not apply to —(a)income derived between 12 December 2018 and 18 February 2025 (both dates inclusive) from the leasing of a container or intermodal equipment that is acquired by the approved container investment enterprise or the approved related party by way of a finance lease entered into with an entity that is not an approved related party; or(b)income derived on or after 19 February 2025 from the leasing of a container or intermodal equipment that is acquired by the approved container investment enterprise or the approved related party by way of a finance lease not treated as a sale under section 10C, entered into with an entity that is not an approved related party.”; and

In the ITA, in section 43Q(4A), replace “2026” with “2031”.

In the ITA, in section 43R —(a)replace subsection (1) with —“(1) Despite section 43, the Minister may by regulations provide that tax at the rate specified in the first column of the following table, is to be levied and paid for each year of assessment upon such income as the Minister may specify that is derived on or after a prescribed date by an approved insurance broker set out opposite that rate in the second column of the table, from the provision of such direct insurance broking, reinsurance broking or advisory services relating to the insurance sector as may be prescribed:Tax rateApproved insurance broker10%An approved insurance broker whose approval is granted between 1 April 2008 and 18 February 2025 (both dates inclusive)10% or 15%An approved insurance broker whose approval is granted between 19 February 2025 and 31 December 2028 (both dates inclusive)”; and(b)after subsection (2), insert —“(2A) Regulations made under subsection (1) 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.”.

“(1) Despite section 43, the Minister may by regulations provide that tax at the rate specified in the first column of the following table, is to be levied and paid for each year of assessment upon such income as the Minister may specify that is derived on or after a prescribed date by an approved insurance broker set out opposite that rate in the second column of the table, from the provision of such direct insurance broking, reinsurance broking or advisory services relating to the insurance sector as may be prescribed:Tax rateApproved insurance broker10%An approved insurance broker whose approval is granted between 1 April 2008 and 18 February 2025 (both dates inclusive)10% or 15%An approved insurance broker whose approval is granted between 19 February 2025 and 31 December 2028 (both dates inclusive)”; and

“(2A) Regulations made under subsection (1) 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.”.

In the ITA, in section 43U —(a)in subsection (2), replace “2026” with “2031”;(b)after subsection (5J), insert —“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.(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.(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).(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).(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).(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).(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.”;(c)above subsection (6), insert — “General provisions”;(d)in subsection (6), after “company”, insert “or approved SPV”;(e)in subsection (8), in the definition of “corporate service”, after “an approved company”, insert “or its approved SPV”;(f)in subsection (8), in the definition of “corporate service”, after “the approved company”, insert “or approved SPV”;(g)in subsection (8), in the definition of “corporate service”, after “(5I)”, insert “(or those provisions as applied by subsection (5O))”;(h)in subsection (8), after the definition of “freight forwarding and logistics service”, insert —“ “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;”;(i)in subsection (8), in the definition of “service approval date”, after “(5B)”, insert “or an approved SPV under subsection (5L) or (5Q)”;(j)in subsection (8), in the definition of “service approval date”, after “that company”, insert “or SPV”;(k)in subsection (8), in the definition of “service approval date”, replace “the company to its approved related company” with “the company or SPV to the company’s approved related company”;(l)in subsection (8), in the definition of “shipping‑related business”, in paragraph (q), after “offshore renewable energy activity”, insert “, renewable energy activity”;(m)in subsection (8), in the definition of “shipping‑related business”, after paragraph (q), insert —“(r)maritime technology service;”;(n)in subsection (8), in the definition of “shipping‑related support service”, in paragraph (f), replace the full‑stop at the end with a semi‑colon;(o)in subsection (8), in the definition of “shipping‑related support service”, after paragraph (f), insert —“(g)maritime technology service;”;(p)in subsection (8), after the definition of “shipping‑related support service”, insert —“ “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;”;(q)in subsection (9)(a), replace “and (5CA)” with “, (5CA), (5K), (5L), (5M) and (5Q)”;(r)in subsection (9)(a) and (b), after “approved company” wherever it appears, insert “or approved SPV (as the case may be)”; and(s)in subsection (9)(b), after “and (5I)”, insert “(or those provisions as applied by subsection (5O))”.

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.

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.

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).

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).

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).

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).

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.”;

In the ITA, in section 45G(2)(a) and (b) and (5), replace “2025” with “2030”.

In the ITA, in section 83, after subsection (3), insert —“(4) However, the name of the taxpayer may be disclosed in the publication mentioned in subsection (3) with the taxpayer’s consent.(5) Subsection (4) applies to any proceedings before the Board that are heard before, on or after the date of commencement of section 41 of the Finance (Income Taxes) Act 2025.”.

“(4) However, the name of the taxpayer may be disclosed in the publication mentioned in subsection (3) with the taxpayer’s consent.

Subsection (4) applies to any proceedings before the Board that are heard before, on or after the date of commencement of section 41 of the Finance (Income Taxes) Act 2025.”.

In the ITA, after section 92J, insert —“Rebate for company for listing shares on stock exchange in Singapore92K.—(1) This section applies to a company the ordinary shares of which —(a)are first listed on a stock exchange in Singapore on a date (called in this section the listing date) between 19 February 2025 and 31 December 2027 (both dates inclusive), by way of a primary listing or a secondary listing; and(b)are offered in conjunction with such listing. (2) For the purposes of this section, the first listing of ordinary shares of a company on a stock exchange includes a relisting of ordinary shares of that company on that stock exchange, at any time after ordinary shares of that company have been delisted from that stock exchange.Approval of approved company(3) The company may apply to the Minister or an authorised body to be approved for the purposes of this section. (4) An application under subsection (3) must be made within such period as the Minister or authorised body may allow, and must be accompanied by such information and documents as the Minister or authorised body may require.(5) A company that is approved as a financial sector incentive company for the purposes of section 43J(1B), or its holding company, is not eligible to make an application under subsection (3).(6) The Minister or authorised body may, subject to such conditions (including conditions subsequent) as the Minister or authorised body may impose, approve a company as an approved company for the purposes of this section.(7) An approval under subsection (6) is for a single period of 5 years (called in this section the incentive period) starting from the first day of the month in which the listing date falls, and the earliest date on which an approval may take effect is 1 February 2025.(8) It is a condition of approval of an approved company for its ordinary shares to remain listed on a stock exchange in Singapore throughout its incentive period, starting from its listing date.(9) No approval under this section may be granted after 31 December 2027.Tax rebate for approved company(10) The following is to be made to an approved company:(a)where its ordinary shares are listed on a stock exchange in Singapore by way of a primary listing in the whole or part of the basis period for a year of assessment that is within its incentive period — a rebate computed in accordance with the following formula:where —(i)A is —(A)where the ordinary shares are so listed in the whole of the basis period within its incentive period — the number of months in that basis period; (B)where only a part of the basis period during which the ordinary shares are so listed falls within its incentive period — the number of months in that part;(C)where the ordinary shares are so listed in a part of the basis period within its incentive period before the occurrence of a listing conversion — the number of months in that part before the month in which the listing conversion occurs; or(D)where the ordinary shares are so listed in a part of the basis period within its incentive period after the occurrence of a listing conversion — the number of months in that part beginning with the month in which the listing conversion occurs;(ii)B is the total number of months in the basis period; and(iii)C is the tax payable by the approved company for that year of assessment as determined under subsection (11);(b)where its ordinary shares are listed on a stock exchange in Singapore by way of a secondary listing in the whole or part of the basis period for a year of assessment that is within its incentive period — a rebate computed in accordance with the following formula:where —(i)A is —(A)where the ordinary shares are so listed in the whole of the basis period within its incentive period — the number of months in that basis period; (B)where only a part of the basis period during which the ordinary shares are so listed falls within its incentive period — the number of months in that part;(C)where the ordinary shares are so listed in a part of the basis period within its incentive period before the occurrence of a listing conversion — the number of months in that part before the month in which the listing conversion occurs; or(D)where the ordinary shares are so listed in a part of the basis period within its incentive period after the occurrence of a listing conversion — the number of months in that part beginning with the month in which the listing conversion occurs;(ii)B is the total number of months in the basis period; and(iii)C is the tax payable by the approved company for that year of assessment as determined under subsection (11).(11) In subsection (10)(a)(iii) and (b)(iii), the tax payable by the approved company for a year of assessment is the amount of tax levied on the chargeable income of the approved company under Part 11 for that year of assessment (excluding any tax levied under section 43(3), (3A), (3B) and (3C)) —(a)before making any set‑off under Part 13;(b)before making any remission of the tax under any other provision of this Part; and(c)after making any deduction of tax credit under Part 14.(12) The rebate to be made to an approved company against the tax payable for each year of assessment must not exceed —(a)if the approved company has a market capitalisation of at least $1 billion on the listing date — $6 million; or(b)if the approved company has a market capitalisation of less than $1 billion on the listing date — $3 million.(13) If a listing conversion occurs in the basis period for a year of assessment, then the maximum amount of rebate to be made to the approved company against the tax payable for that year of assessment is to be computed as follows:(a)the rebate against the tax payable for that year of assessment, pro‑rated for the period before the listing conversion, must not exceed an amount determined by , where —(i)A is the amount mentioned in subsection (12)(a) or (b) (whichever is applicable);(ii)B is the number of months in the part of the basis period ending before the month in which the listing conversion occurs; and(iii)C is the total number of months in the basis period for the year of assessment;(b)the rebate against the tax payable for that year of assessment, pro‑rated for the period after the listing conversion, must not exceed an amount determined by , where —(i)A1 is —(A)if the approved company has a market capitalisation of at least $1 billion on the date of occurrence of the listing conversion — $6 million; or(B)if the approved company has a market capitalisation of less than $1 billion on the date of occurrence of the listing conversion — $3 million; and(ii)B and C are the number of months mentioned in paragraph (a)(ii) and (iii), respectively.(14) In this section, a listing conversion occurs when ordinary shares of an approved company which are listed by way of a primary listing on a stock exchange in Singapore, then becomes listed on that or another stock exchange in Singapore by way of a secondary listing, or vice versa.Nomination of subsidiaries for rebate (15) A company making an application under subsection (3) may, at any time before the application is approved —(a)nominate for the approval of the Minister or authorised body, up to 3 of its eligible subsidiaries to which the rebate is to be made; and(b)where more than one eligible subsidiary is nominated, specify the order of priority in which the rebate is to be made to the nominees under subsection (26), which is to remain the same throughout the company’s incentive period.(16) If less than 3 eligible subsidiaries are approved under subsection (15)(a), an approved company may at any time after its approval, nominate for the approval of the Minister or authorised body one or more of its other eligible subsidiaries to which the rebate is to be made, subject to the following:(a)an approved company may not have more than 3 eligible subsidiaries approved as its nominees at any one time;(b)where more than one eligible subsidiary is nominated under this subsection, the approved company must in its application specify the order of priority in which the rebate is to be made to the nominees under subsection (26), which is to remain the same throughout the approved company’s incentive period;(c)in the order of priority mentioned in paragraph (b) —(i)an eligible subsidiary that is approved under this subsection ranks below any other eligible subsidiary approved under subsection (15)(a); and(ii)an eligible subsidiary that is approved under this subsection ranks below any other eligible subsidiary whose effective date of approval is earlier than its date of approval. (17) An approval of a nominee under subsection (15)(a) is effective from the first day of the month in which the listing date falls, or such other date as the Minister or authorised body may allow.(18) An approval of a nominee under subsection (16) is effective from —(a)the later of the following:(i)the first day of the month in which the nomination is made; (ii)the first day of the month in which the nominee first becomes an eligible subsidiary of the approved company; or(b)such other date as the Minister or authorised body may allow.(19) In this section, an “eligible subsidiary” of a company is a company that is wholly‑owned (directly or indirectly) by the company and has a financial year that ends on the same day as that of the company.(20) If any nominee approved by the Minister or authorised body (including one approved under subsection (22)) is in liquidation, ceases to carry on a trade or business in Singapore or ceases to exist at any time during the basis period for a year of assessment, then the approval of that nominee is treated as revoked as of the first day of that basis period in which the date of commencement of the liquidation or cessation falls.(21) If any nominee approved by the Minister or authorised body (including one approved under subsection (22)) —(a)ceases to be wholly‑owned (directly or indirectly) by the approved company concerned; or (b)ceases to have a financial year that ends on the same day as that of the approved company,at any time during the basis period for a year of assessment, then the approval of that nominee is treated as revoked as of the first day of that basis period.(22) In a case mentioned in subsection (20) or (21), the approved company may, within such period as the Minister or authorised body may allow, apply to the Minister or authorised body for the approval of another of its eligible subsidiaries as a replacement nominee.(23) An approval of the replacement nominee is effective from —(a)the later of the following: (i)the date the nominee being replaced is treated as revoked under subsection (20) or (21);(ii)the first day of the month in which the replacement nominee first becomes an eligible subsidiary of the approved company; or(b)such other date as the Minister or authorised body may allow,and the replacement nominee assumes the position of the nominee being replaced in the order of priority specified under subsection (15)(b), or subsection (16)(b) read with subsection (16)(c), for the purpose of making the rebate.(24) A company that is approved as a financial sector incentive company for the purposes of section 43J(1B), or its holding company, may not be nominated under subsection (15)(a), (16) or (22).(25) The application under subsection (15), (16) or (22) must be accompanied by such information and documents as the Minister or authorised body may require.(26) Where an approval is granted in respect of one or more nominees (including a replacement nominee) of an approved company, the rebate to be made to the approved company (as determined by subsections (10) to (13)) is instead to be made —(a)first against the tax payable by the approved company in a year of assessment; and (b)then against the tax payable by those approved nominees in the same year of assessment in the order of priority specified under subsection (15)(b), or subsection (16)(b) read with subsection (16)(c),until the applicable maximum amount of rebate under subsection (12)(a) or (b) or (13) (as the case may be) is reached; and subsections (10) and (11) apply with the necessary modifications to the making of the rebate against the tax payable by an approved nominee (including a replacement nominee) as they apply to the making of the rebate against the tax payable by the approved company.Revocation of approval of approved company(27) Section 105R applies to a failure to comply with a condition of approval (including the condition in subsection (8)) of an approved company under this section with the following modifications:(a)a reference to a tax incentive is to a rebate under this section;(b)a reference to the application of a tax incentive to a person’s income is to the making of a rebate under this section against any tax payable by the approved company or its nominee;(c)the following subsections apply in place of section 105R(6): “(6) Where — (a)a rebate has been made against the tax payable by the approved company or its nominee for a year of assessment; (b)the full or a part of the amount of the rebate would not have been so made if the company had no incentive period, or its incentive period had been reduced, owing to its not being an approved company under this section on any date in the basis period for that year of assessment; and (c)the approval is revoked under this section with effect from and including that date, the full or part of the amount of rebate as mentioned in paragraph (b) (less any remission of tax under any provision in this Part (other than section 92)) is recoverable by the Comptroller as a debt due to the Government from the company or the nominee. (6A) For the purpose of subsection (6) — (a)the amount recoverable is payable within one month after the service of a notice on the company or the nominee or such further time as the Comptroller may allow, subject to such terms and conditions as the Comptroller may impose, and in the manner stated in the notice; and (b)sections 57, 87(1) and (2), 89 and 90 apply to the collection and recovery by the Comptroller of that amount.”.Miscellaneous(28) A reference to a company in this section excludes a VCC.”.

For the purposes of this section, the first listing of ordinary shares of a company on a stock exchange includes a relisting of ordinary shares of that company on that stock exchange, at any time after ordinary shares of that company have been delisted from that stock exchange.

The company may apply to the Minister or an authorised body to be approved for the purposes of this section.

An application under subsection (3) must be made within such period as the Minister or authorised body may allow, and must be accompanied by such information and documents as the Minister or authorised body may require.

A company that is approved as a financial sector incentive company for the purposes of section 43J(1B), or its holding company, is not eligible to make an application under subsection (3).

The Minister or authorised body may, subject to such conditions (including conditions subsequent) as the Minister or authorised body may impose, approve a company as an approved company for the purposes of this section.

An approval under subsection (6) is for a single period of 5 years (called in this section the incentive period) starting from the first day of the month in which the listing date falls, and the earliest date on which an approval may take effect is 1 February 2025.

It is a condition of approval of an approved company for its ordinary shares to remain listed on a stock exchange in Singapore throughout its incentive period, starting from its listing date.

No approval under this section may be granted after 31 December 2027.

The following is to be made to an approved company:(a)where its ordinary shares are listed on a stock exchange in Singapore by way of a primary listing in the whole or part of the basis period for a year of assessment that is within its incentive period — a rebate computed in accordance with the following formula:where —(i)A is —(A)where the ordinary shares are so listed in the whole of the basis period within its incentive period — the number of months in that basis period; (B)where only a part of the basis period during which the ordinary shares are so listed falls within its incentive period — the number of months in that part;(C)where the ordinary shares are so listed in a part of the basis period within its incentive period before the occurrence of a listing conversion — the number of months in that part before the month in which the listing conversion occurs; or(D)where the ordinary shares are so listed in a part of the basis period within its incentive period after the occurrence of a listing conversion — the number of months in that part beginning with the month in which the listing conversion occurs;(ii)B is the total number of months in the basis period; and(iii)C is the tax payable by the approved company for that year of assessment as determined under subsection (11);(b)where its ordinary shares are listed on a stock exchange in Singapore by way of a secondary listing in the whole or part of the basis period for a year of assessment that is within its incentive period — a rebate computed in accordance with the following formula:where —(i)A is —(A)where the ordinary shares are so listed in the whole of the basis period within its incentive period — the number of months in that basis period; (B)where only a part of the basis period during which the ordinary shares are so listed falls within its incentive period — the number of months in that part;(C)where the ordinary shares are so listed in a part of the basis period within its incentive period before the occurrence of a listing conversion — the number of months in that part before the month in which the listing conversion occurs; or(D)where the ordinary shares are so listed in a part of the basis period within its incentive period after the occurrence of a listing conversion — the number of months in that part beginning with the month in which the listing conversion occurs;(ii)B is the total number of months in the basis period; and(iii)C is the tax payable by the approved company for that year of assessment as determined under subsection (11).

In subsection (10)(a)(iii) and (b)(iii), the tax payable by the approved company for a year of assessment is the amount of tax levied on the chargeable income of the approved company under Part 11 for that year of assessment (excluding any tax levied under section 43(3), (3A), (3B) and (3C)) —(a)before making any set‑off under Part 13;(b)before making any remission of the tax under any other provision of this Part; and(c)after making any deduction of tax credit under Part 14.

The rebate to be made to an approved company against the tax payable for each year of assessment must not exceed —(a)if the approved company has a market capitalisation of at least $1 billion on the listing date — $6 million; or(b)if the approved company has a market capitalisation of less than $1 billion on the listing date — $3 million.

If a listing conversion occurs in the basis period for a year of assessment, then the maximum amount of rebate to be made to the approved company against the tax payable for that year of assessment is to be computed as follows:(a)the rebate against the tax payable for that year of assessment, pro‑rated for the period before the listing conversion, must not exceed an amount determined by , where —(i)A is the amount mentioned in subsection (12)(a) or (b) (whichever is applicable);(ii)B is the number of months in the part of the basis period ending before the month in which the listing conversion occurs; and(iii)C is the total number of months in the basis period for the year of assessment;(b)the rebate against the tax payable for that year of assessment, pro‑rated for the period after the listing conversion, must not exceed an amount determined by , where —(i)A1 is —(A)if the approved company has a market capitalisation of at least $1 billion on the date of occurrence of the listing conversion — $6 million; or(B)if the approved company has a market capitalisation of less than $1 billion on the date of occurrence of the listing conversion — $3 million; and(ii)B and C are the number of months mentioned in paragraph (a)(ii) and (iii), respectively.

In this section, a listing conversion occurs when ordinary shares of an approved company which are listed by way of a primary listing on a stock exchange in Singapore, then becomes listed on that or another stock exchange in Singapore by way of a secondary listing, or vice versa.

A company making an application under subsection (3) may, at any time before the application is approved —(a)nominate for the approval of the Minister or authorised body, up to 3 of its eligible subsidiaries to which the rebate is to be made; and(b)where more than one eligible subsidiary is nominated, specify the order of priority in which the rebate is to be made to the nominees under subsection (26), which is to remain the same throughout the company’s incentive period.

If less than 3 eligible subsidiaries are approved under subsection (15)(a), an approved company may at any time after its approval, nominate for the approval of the Minister or authorised body one or more of its other eligible subsidiaries to which the rebate is to be made, subject to the following:(a)an approved company may not have more than 3 eligible subsidiaries approved as its nominees at any one time;(b)where more than one eligible subsidiary is nominated under this subsection, the approved company must in its application specify the order of priority in which the rebate is to be made to the nominees under subsection (26), which is to remain the same throughout the approved company’s incentive period;(c)in the order of priority mentioned in paragraph (b) —(i)an eligible subsidiary that is approved under this subsection ranks below any other eligible subsidiary approved under subsection (15)(a); and(ii)an eligible subsidiary that is approved under this subsection ranks below any other eligible subsidiary whose effective date of approval is earlier than its date of approval.

An approval of a nominee under subsection (15)(a) is effective from the first day of the month in which the listing date falls, or such other date as the Minister or authorised body may allow.

An approval of a nominee under subsection (16) is effective from —(a)the later of the following:(i)the first day of the month in which the nomination is made; (ii)the first day of the month in which the nominee first becomes an eligible subsidiary of the approved company; or(b)such other date as the Minister or authorised body may allow.

In this section, an “eligible subsidiary” of a company is a company that is wholly‑owned (directly or indirectly) by the company and has a financial year that ends on the same day as that of the company.

If any nominee approved by the Minister or authorised body (including one approved under subsection (22)) is in liquidation, ceases to carry on a trade or business in Singapore or ceases to exist at any time during the basis period for a year of assessment, then the approval of that nominee is treated as revoked as of the first day of that basis period in which the date of commencement of the liquidation or cessation falls.

If any nominee approved by the Minister or authorised body (including one approved under subsection (22)) —(a)ceases to be wholly‑owned (directly or indirectly) by the approved company concerned; or (b)ceases to have a financial year that ends on the same day as that of the approved company,at any time during the basis period for a year of assessment, then the approval of that nominee is treated as revoked as of the first day of that basis period.

In a case mentioned in subsection (20) or (21), the approved company may, within such period as the Minister or authorised body may allow, apply to the Minister or authorised body for the approval of another of its eligible subsidiaries as a replacement nominee.

An approval of the replacement nominee is effective from —(a)the later of the following: (i)the date the nominee being replaced is treated as revoked under subsection (20) or (21);(ii)the first day of the month in which the replacement nominee first becomes an eligible subsidiary of the approved company; or(b)such other date as the Minister or authorised body may allow,and the replacement nominee assumes the position of the nominee being replaced in the order of priority specified under subsection (15)(b), or subsection (16)(b) read with subsection (16)(c), for the purpose of making the rebate.

A company that is approved as a financial sector incentive company for the purposes of section 43J(1B), or its holding company, may not be nominated under subsection (15)(a), (16) or (22).

The application under subsection (15), (16) or (22) must be accompanied by such information and documents as the Minister or authorised body may require.

Where an approval is granted in respect of one or more nominees (including a replacement nominee) of an approved company, the rebate to be made to the approved company (as determined by subsections (10) to (13)) is instead to be made —(a)first against the tax payable by the approved company in a year of assessment; and (b)then against the tax payable by those approved nominees in the same year of assessment in the order of priority specified under subsection (15)(b), or subsection (16)(b) read with subsection (16)(c),until the applicable maximum amount of rebate under subsection (12)(a) or (b) or (13) (as the case may be) is reached; and subsections (10) and (11) apply with the necessary modifications to the making of the rebate against the tax payable by an approved nominee (including a replacement nominee) as they apply to the making of the rebate against the tax payable by the approved company.

Section 105R applies to a failure to comply with a condition of approval (including the condition in subsection (8)) of an approved company under this section with the following modifications:(a)a reference to a tax incentive is to a rebate under this section;(b)a reference to the application of a tax incentive to a person’s income is to the making of a rebate under this section against any tax payable by the approved company or its nominee;(c)the following subsections apply in place of section 105R(6): “(6) Where — (a)a rebate has been made against the tax payable by the approved company or its nominee for a year of assessment; (b)the full or a part of the amount of the rebate would not have been so made if the company had no incentive period, or its incentive period had been reduced, owing to its not being an approved company under this section on any date in the basis period for that year of assessment; and (c)the approval is revoked under this section with effect from and including that date, the full or part of the amount of rebate as mentioned in paragraph (b) (less any remission of tax under any provision in this Part (other than section 92)) is recoverable by the Comptroller as a debt due to the Government from the company or the nominee. (6A) For the purpose of subsection (6) — (a)the amount recoverable is payable within one month after the service of a notice on the company or the nominee or such further time as the Comptroller may allow, subject to such terms and conditions as the Comptroller may impose, and in the manner stated in the notice; and (b)sections 57, 87(1) and (2), 89 and 90 apply to the collection and recovery by the Comptroller of that amount.”.

A reference to a company in this section excludes a VCC.”.

This section applies to a company the ordinary shares of which —(a)are first listed on a stock exchange in Singapore on a date (called in this section the listing date) between 19 February 2025 and 31 December 2027 (both dates inclusive), by way of a primary listing or a secondary listing; and(b)are offered in conjunction with such listing.

In the ITA, after section 92K (as inserted by section 42), insert —“Remission of tax for companies for year of assessment 2025 and cash grant for companies92L.—(1) Where the Comptroller is satisfied that the remission of tax would be beneficial to a company, then there is to be remitted the tax payable for the year of assessment 2025 by the company of an amount equal to the lower of the following:(a)50% of the tax payable for that year of assessment (excluding any tax levied under section 43(3), (3A), (3B) and (3C)), less the cash grant of $2,000 made to the company under subsection (3), where applicable; (b)$40,000, less the cash grant of $2,000 made to the company under subsection (3), where applicable.(2) However, where 50% of the tax payable under subsection (1)(a) is less than the cash grant of $2,000, the amount in subsection (1)(a) is nil.(3) Subject to subsection (4), where a company has made a CPF contribution in respect of at least one local employee in the calendar year 2024 in accordance with regulation 2(1) of the Central Provident Fund Regulations (called in this section the time requirement), there is to be made to the company a cash grant of $2,000.(4) Unless the Comptroller otherwise permits, no cash grant may be made to a company (X) if, at the time of disbursement —(a)X is not carrying on a trade or business (including the activity of holding any investments);(b)X is in liquidation;(c)X is under receivership in respect of all of its properties; or(d)X has ceased to exist.(5) The Comptroller may waive the time requirement under subsection (3) if the Comptroller is satisfied that it is just and equitable to do so. (6) The cash grant under subsection (3) is exempt from tax in the hands of the company. (7) For the purpose of subsection (3) —“central hirer” and “central hiring arrangement” have the meanings given by section 14ZG(5);“CPF contribution” means a contribution to the Central Provident Fund that is obligatory under section 7(1) of the Central Provident Fund Act 1953;“employee”, in relation to a company, means —(a)an individual who is an employee of the company for any period in the calendar year 2024 and is on the payroll of the company for that period;(b)an individual —(i)who is engaged by the central hirer of a central hiring arrangement for a group of related parties that includes the company;(ii)who is deployed to work solely for the company for any period in the calendar year 2024;(iii)who is on the payroll of the central hirer or the company for that period; and (iv)whose salary and other remuneration for that period (including any CPF contribution in respect of the individual) is borne (directly or indirectly) by the company; or (c)an individual —(i)who, being an employee of another person that is a related party of the company (called in this subsection and subsection (8) the employer), is seconded to a position in the company under a bona fide commercial arrangement to work solely for the company for any period in the calendar year 2024;(ii)who is on the payroll of the employer or the company for that period; and (iii)whose salary and other remuneration for that period (including any CPF contribution in respect of the individual) is borne (directly or indirectly) by the company, but excludes any individual who is a shareholder and also a director of the company;“local employee” means a Singapore citizen or Singapore permanent resident who is an employee of the company.(8) For the purpose of determining whether the individual mentioned in paragraph (b) or (c) of the definition of “employee” in subsection (7) is also an employee of the central hirer or the employer by virtue of paragraph (a) of that definition, the period mentioned in paragraph (b) or (c) (as the case may be) is to be disregarded for the purpose of paragraph (a) of that definition.”.

Where the Comptroller is satisfied that the remission of tax would be beneficial to a company, then there is to be remitted the tax payable for the year of assessment 2025 by the company of an amount equal to the lower of the following:(a)50% of the tax payable for that year of assessment (excluding any tax levied under section 43(3), (3A), (3B) and (3C)), less the cash grant of $2,000 made to the company under subsection (3), where applicable; (b)$40,000, less the cash grant of $2,000 made to the company under subsection (3), where applicable.

“central hirer” and “central hiring arrangement” have the meanings given by section 14ZG(5);

“CPF contribution” means a contribution to the Central Provident Fund that is obligatory under section 7(1) of the Central Provident Fund Act 1953;

“employee”, in relation to a company, means —(a)an individual who is an employee of the company for any period in the calendar year 2024 and is on the payroll of the company for that period;(b)an individual —(i)who is engaged by the central hirer of a central hiring arrangement for a group of related parties that includes the company;(ii)who is deployed to work solely for the company for any period in the calendar year 2024;(iii)who is on the payroll of the central hirer or the company for that period; and (iv)whose salary and other remuneration for that period (including any CPF contribution in respect of the individual) is borne (directly or indirectly) by the company; or (c)an individual —(i)who, being an employee of another person that is a related party of the company (called in this subsection and subsection (8) the employer), is seconded to a position in the company under a bona fide commercial arrangement to work solely for the company for any period in the calendar year 2024;(ii)who is on the payroll of the employer or the company for that period; and (iii)whose salary and other remuneration for that period (including any CPF contribution in respect of the individual) is borne (directly or indirectly) by the company, but excludes any individual who is a shareholder and also a director of the company;

“local employee” means a Singapore citizen or Singapore permanent resident who is an employee of the company.

However, where 50% of the tax payable under subsection (1)(a) is less than the cash grant of $2,000, the amount in subsection (1)(a) is nil.

Subject to subsection (4), where a company has made a CPF contribution in respect of at least one local employee in the calendar year 2024 in accordance with regulation 2(1) of the Central Provident Fund Regulations (called in this section the time requirement), there is to be made to the company a cash grant of $2,000.

Unless the Comptroller otherwise permits, no cash grant may be made to a company (X) if, at the time of disbursement —(a)X is not carrying on a trade or business (including the activity of holding any investments);(b)X is in liquidation;(c)X is under receivership in respect of all of its properties; or(d)X has ceased to exist.

The Comptroller may waive the time requirement under subsection (3) if the Comptroller is satisfied that it is just and equitable to do so.

The cash grant under subsection (3) is exempt from tax in the hands of the company.

For the purpose of subsection (3) —

For the purpose of determining whether the individual mentioned in paragraph (b) or (c) of the definition of “employee” in subsection (7) is also an employee of the central hirer or the employer by virtue of paragraph (a) of that definition, the period mentioned in paragraph (b) or (c) (as the case may be) is to be disregarded for the purpose of paragraph (a) of that definition.”.

In the ITA, after section 93, insert —“Modification of section 93 for repayment of tax for training allowance under Workfare Training Support scheme93AA.—(1) Section 93 (Repayment of tax) applies to enable a person who had paid tax in respect of any payment mentioned in section 13(1)(zpa) that ought not to have been paid because of the backdating of the date of commencement of section 5(1)(a) of the Finance (Income Taxes) Act 2025.(2) In the application of section 93 under subsection (1), section 93(2) is replaced with the following: “(2) A claim for repayment must be made to the Comptroller by 31 December 2029.”.”.

In the application of section 93 under subsection (1), section 93(2) is replaced with the following: “(2) A claim for repayment must be made to the Comptroller by 31 December 2029.”.”.

Section 93 (Repayment of tax) applies to enable a person who had paid tax in respect of any payment mentioned in section 13(1)(zpa) that ought not to have been paid because of the backdating of the date of commencement of section 5(1)(a) of the Finance (Income Taxes) Act 2025.

In the ITA, in section 93B —(a)in subsection (2), in the definition of “unutilised RICs”, in paragraph (b), after “subsection 40(a)”, insert “(including that provision as applied by subsections (14A) and (20B))”;(b)in subsections (5)(i), (12)(h) and (23)(a), replace “after” with “starting from”;(c)after subsection (14), insert —“(14A) Subsections (38)(b), (40), (41) and (42) apply with the necessary modifications to an amendment of a letter of award under subsection (13) or (14) as they apply to an amendment of a letter of award under subsection (35)(a).”;(d)after subsection (20), insert —“(20A) The approving authority may, in any prescribed circumstances, on the application by an awardee company or on its own initiative, amend any matter stated in a letter of confirmation given to the awardee company.(20B) Where an amendment is made to a letter of confirmation under subsection (20A) —(a)a reference in this section to that matter in relation to the awardee company is to that matter as so amended; and(b)subsections (38)(b), (40), (41) and (42) apply with the necessary modifications to the amendment as they apply to an amendment of a letter of award under subsection (35)(a), and for this purpose, a reference to the letter of award in subsection (38)(b) is to the letter of confirmation.”;(e)in subsection (23)(b), replace “, and other matters relating to, such election” with “such election and the circumstances under which such election is treated as revoked, and other matters relating to such election”;(f)replace subsection (31) with —“(31) The Comptroller is to make a monetary payment equivalent to the amount of those RICs to the awardee company on or before the payout date or payment date, to the extent that they have not been —(a)revoked, or treated as revoked under the regulations; or(b)debited under subsection (40)(a) (including that provision as applied by subsections (14A) and (20B)).”;(g)in subsection (43)(c), after “approving authority”, insert “, within the prescribed period after the date of amalgamation,”;(h)in subsection (45), replace paragraph (b) with —“(b)in the case of subsection (43)(a)(ii), the unutilised RICs —(i)are to be credited to an RIC account kept or to be kept for Y; and(ii)are treated as having been given to Y on the date they were given to X by the approving authority under subsection (17), except that this does not affect the debit of any RICs from Y’s RIC account carried out before those unutilised RICs are credited to Y’s RIC account under sub‑paragraph (i).”;(i)after subsection (45), insert —“(45A) If an application is not made in accordance with subsection (43)(c), or if such an application is refused, then the RICs mentioned in subsection (43)(a)(i) or (ii) are treated as forfeited.(45B) Subsections (45) and (45A) apply despite anything in section 215G(c) of the Companies Act 1967 or section 34C.”;(j)in subsection (46), replace paragraph (c) with —“(c)to apply with modifications the provisions of this section in relation to Y or to each Y as they apply in relation to X, if Y satisfies such requirements as may be prescribed;”;(k)replace paragraph (e) with —“(e)to provide, in any prescribed circumstances, for the recovery from Y of any amount of RICs that have been used to offset any due tax of Y, and for any RICs that were debited from X’s RIC account to offset that due tax to be credited back to the account;(ea)to provide that any amount of RICs —(i)credited back to X’s RIC account under regulations made for the purpose in paragraph (e); or (ii)otherwise wrongly debited from X’s RIC account and credited back to that account, is treated as having been given to X on the date that it was first given to X under subsection (17), but without affecting any previous debit of RICs from X’s RIC account; and”; and (l)after subsection (48), insert —“Recovery of RICs for erroneous offsetting of tax, etc. (48A) If —(a)an amount of RICs of an awardee company (X) is used to offset the due tax of any company (including X); or (b)a monetary payment equivalent to an amount of RICs of an awardee company (also called X) is paid to X under subsection (31),otherwise than in accordance with this section or the regulations made under subsection (51), then the amount of the due tax so offset or the amount paid to X is recoverable by the Comptroller from the company or X (as the case may be) as a debt due to the Government.(48B) For the purposes of subsection (48A) —(a)the amount recoverable under that provision is to be paid at the place stated in a notice served by the Comptroller on the company or X (as the case may be) within 30 days after the service of the notice;(b)the Comptroller may, in the Comptroller’s discretion and subject to such terms and conditions as the Comptroller may impose, extend the time limit within which payment is to be made; and(c)sections 86(1) to (6), 87(1) and (2), 89, 90 and 91 apply to the collection and recovery by the Comptroller of that amount as they apply to the collection and recovery of tax.(48C) In a case mentioned in subsection (48A) —(a)the amount of X’s RICs mentioned in that provision is to be credited back to X’s RIC account; and (b)those RICs so credited back are treated as having been given to X on the date that they were first given to X by the approving authority under subsection (17), except that this does not affect any debit of RICs from X’s RIC account carried out before those RICs are so credited back.(48D) Where —(a)an amount of RICs is credited back to the RIC account of an awardee company (Y) under subsection (48C) or any regulations made under subsection (51); but(b)the payout date or payment date (as the case may be) for those RICs has passed,then subsections (31) and (32) apply for the purpose of enabling a monetary payment equivalent to the amount of those RICs to be made to Y as if a reference to the payout date or payment date were a reference to a prescribed date after the RICs are credited back to Y’s RIC account.”.

“(14A) Subsections (38)(b), (40), (41) and (42) apply with the necessary modifications to an amendment of a letter of award under subsection (13) or (14) as they apply to an amendment of a letter of award under subsection (35)(a).”;

“(20A) The approving authority may, in any prescribed circumstances, on the application by an awardee company or on its own initiative, amend any matter stated in a letter of confirmation given to the awardee company.

Where an amendment is made to a letter of confirmation under subsection (20A) —(a)a reference in this section to that matter in relation to the awardee company is to that matter as so amended; and(b)subsections (38)(b), (40), (41) and (42) apply with the necessary modifications to the amendment as they apply to an amendment of a letter of award under subsection (35)(a), and for this purpose, a reference to the letter of award in subsection (38)(b) is to the letter of confirmation.”;

“(31) The Comptroller is to make a monetary payment equivalent to the amount of those RICs to the awardee company on or before the payout date or payment date, to the extent that they have not been —(a)revoked, or treated as revoked under the regulations; or(b)debited under subsection (40)(a) (including that provision as applied by subsections (14A) and (20B)).”;

“(45A) If an application is not made in accordance with subsection (43)(c), or if such an application is refused, then the RICs mentioned in subsection (43)(a)(i) or (ii) are treated as forfeited.

Subsections (45) and (45A) apply despite anything in section 215G(c) of the Companies Act 1967 or section 34C.”;

If —(a)an amount of RICs of an awardee company (X) is used to offset the due tax of any company (including X); or (b)a monetary payment equivalent to an amount of RICs of an awardee company (also called X) is paid to X under subsection (31),otherwise than in accordance with this section or the regulations made under subsection (51), then the amount of the due tax so offset or the amount paid to X is recoverable by the Comptroller from the company or X (as the case may be) as a debt due to the Government.

For the purposes of subsection (48A) —(a)the amount recoverable under that provision is to be paid at the place stated in a notice served by the Comptroller on the company or X (as the case may be) within 30 days after the service of the notice;(b)the Comptroller may, in the Comptroller’s discretion and subject to such terms and conditions as the Comptroller may impose, extend the time limit within which payment is to be made; and(c)sections 86(1) to (6), 87(1) and (2), 89, 90 and 91 apply to the collection and recovery by the Comptroller of that amount as they apply to the collection and recovery of tax.

In a case mentioned in subsection (48A) —(a)the amount of X’s RICs mentioned in that provision is to be credited back to X’s RIC account; and (b)those RICs so credited back are treated as having been given to X on the date that they were first given to X by the approving authority under subsection (17), except that this does not affect any debit of RICs from X’s RIC account carried out before those RICs are so credited back.

Where —(a)an amount of RICs is credited back to the RIC account of an awardee company (Y) under subsection (48C) or any regulations made under subsection (51); but(b)the payout date or payment date (as the case may be) for those RICs has passed,then subsections (31) and (32) apply for the purpose of enabling a monetary payment equivalent to the amount of those RICs to be made to Y as if a reference to the payout date or payment date were a reference to a prescribed date after the RICs are credited back to Y’s RIC account.”.

In the ITA, after section 93B, insert —“Recovery of cash grant from companies93C.—(1) Where a company receives a cash grant under any provision of this Part (other than a grant given under section 92B, 92C, 92J or 93B) —(a)without having satisfied all the requirements to qualify for the cash grant; or(b)that is in excess of that which may be given to the company under that provision,the amount of the cash grant or the excess amount of the cash grant (as the case may be) is recoverable by the Comptroller from the company as a debt due to the Government.(2) The Comptroller must send the company a notice specifying the amount to be repaid under subsection (1), and the company must pay the amount at the place stated in the notice within one month after the service of the notice.(3) The Comptroller may, in his or her discretion and subject to such terms and conditions as the Comptroller may impose, extend the time limit within which payment under subsection (2) is to be made.(4) Sections 57, 87(1) and (2), 89 and 90 apply with the necessary modifications to the collection and recovery by the Comptroller of the amounts recoverable under subsection (1) as they apply to the collection and recovery of tax.(5) Without affecting subsections (2), (3) and (4), where an amount of cash grant (other than a grant under section 93B) (amount A) is to be made to a company under a provision of this Part and an amount of another cash grant (other than a grant under section 93B) (amount B) that was previously made to a company under another provision of this Part is recoverable by the Comptroller as a debt due to the Government under subsection (1), section 92B(4), 92C(5) or 92J(6), then —(a)despite the firstmentioned provision, amount A is reduced by amount B; and (b)the amount of the reduction is treated as a repayment by the company of the debt due to the Government.(6) In addition, where an amount of cash grant (other than a grant under section 93B) is to be made to the company under a provision of this Part and any tax, duty, interest or penalty is due from the company —(a)under this Act to the Comptroller of Income Tax;(b)under the Goods and Services Tax Act 1993 to the Comptroller of Goods and Services Tax;(c)under the Property Tax Act 1960 to the Comptroller of Property Tax; or(d)under the Stamp Duties Act 1929 to the Commissioner of Stamp Duties,then —(e)despite that provision, the amount of cash grant to be made by the Comptroller to the company must be reduced by the amount so due; and (f)the amount of the reduction is treated as tax, duty, interest or penalty paid by the company under the relevant Act and must (if it is due under an Act other than this Act) be paid by the Comptroller to the Comptroller of Goods and Services Tax, the Comptroller of Property Tax or the Commissioner of Stamp Duties, as the case may be.(7) Where the amount of cash grant to be made to the company is less than the sum of the amount of cash grant recoverable by the Comptroller from the company under subsection (5) and the amount of tax, duty, interest or penalty due by the company under subsection (6), the Comptroller may determine the amount of reduction to be made under subsection (5) or (6), or both, in a manner that he or she considers reasonable.”.

The Comptroller must send the company a notice specifying the amount to be repaid under subsection (1), and the company must pay the amount at the place stated in the notice within one month after the service of the notice.

The Comptroller may, in his or her discretion and subject to such terms and conditions as the Comptroller may impose, extend the time limit within which payment under subsection (2) is to be made.

Sections 57, 87(1) and (2), 89 and 90 apply with the necessary modifications to the collection and recovery by the Comptroller of the amounts recoverable under subsection (1) as they apply to the collection and recovery of tax.

Without affecting subsections (2), (3) and (4), where an amount of cash grant (other than a grant under section 93B) (amount A) is to be made to a company under a provision of this Part and an amount of another cash grant (other than a grant under section 93B) (amount B) that was previously made to a company under another provision of this Part is recoverable by the Comptroller as a debt due to the Government under subsection (1), section 92B(4), 92C(5) or 92J(6), then —(a)despite the firstmentioned provision, amount A is reduced by amount B; and (b)the amount of the reduction is treated as a repayment by the company of the debt due to the Government.

In addition, where an amount of cash grant (other than a grant under section 93B) is to be made to the company under a provision of this Part and any tax, duty, interest or penalty is due from the company —(a)under this Act to the Comptroller of Income Tax;(b)under the Goods and Services Tax Act 1993 to the Comptroller of Goods and Services Tax;(c)under the Property Tax Act 1960 to the Comptroller of Property Tax; or(d)under the Stamp Duties Act 1929 to the Commissioner of Stamp Duties,then —(e)despite that provision, the amount of cash grant to be made by the Comptroller to the company must be reduced by the amount so due; and (f)the amount of the reduction is treated as tax, duty, interest or penalty paid by the company under the relevant Act and must (if it is due under an Act other than this Act) be paid by the Comptroller to the Comptroller of Goods and Services Tax, the Comptroller of Property Tax or the Commissioner of Stamp Duties, as the case may be.

Where the amount of cash grant to be made to the company is less than the sum of the amount of cash grant recoverable by the Comptroller from the company under subsection (5) and the amount of tax, duty, interest or penalty due by the company under subsection (6), the Comptroller may determine the amount of reduction to be made under subsection (5) or (6), or both, in a manner that he or she considers reasonable.”.

Where a company receives a cash grant under any provision of this Part (other than a grant given under section 92B, 92C, 92J or 93B) —(a)without having satisfied all the requirements to qualify for the cash grant; or(b)that is in excess of that which may be given to the company under that provision,the amount of the cash grant or the excess amount of the cash grant (as the case may be) is recoverable by the Comptroller from the company as a debt due to the Government.

In the ITA, in section 105I, after the definition of “country‑by‑country report”, insert —“ “crypto‑asset reporting framework agreement” or “CARF agreement” means a bilateral or multilateral agreement that is based on the International Standards for Automatic Exchange of Information in Tax Matters pursuant to the Crypto‑Asset Reporting Framework developed by the Organisation for Economic Co‑operation and Development;”.

In the ITA, in section 105K(1) —(a)after paragraph (ab), insert —“(ac)a CARF agreement between —(i)the Government and —(A)the government of another country; or(B)the governments of 2 or more countries; or(ii)the Minister or the Minister’s authorised representative and —(A)the authority of another country that exercises a power or carries out a duty corresponding to a power or duty of the Minister or representative; or(B)the authorities of 2 or more countries that exercise powers or carry out duties corresponding to a power or duty of the Minister or representative;”;(b)in paragraph (b), replace “or (ab)” with “, (ab) or (ac)”; and(c)in paragraph (c), after “(ab)”, insert “, (ac)”.

In the ITA, in section 107 —(a)in subsection (11), after “14EA,”, insert “14EB,”;(b)in subsection (11), after “14M,”, insert “14MA,”;(c)in subsection (17)(a), replace “ordinary shares” with “ordinary shares or preference shares (or both)”;(d)after subsection (18), insert —“(18A) Section 13W(1A) applies for the purpose of determining the exempt income of a company (including a non‑umbrella VCC but excluding an umbrella VCC) from the disposal of shares in a VCC (whether or not an umbrella VCC) (called X) with the following modifications:(a)all references to preference shares in X are omitted;(b)the reference in section 13W(1A)(b)(ii) to the paid‑up share capital of ordinary shares and preference shares in X is to the paid‑up share capital of ordinary shares in X.”;(e)after subsection (20), insert —“(20A) For the purposes of subsection (17A) —“applicable accounting principles”, in relation to a company, means —(a)the accounting principles adopted by the company; or(b)if the company is not required to comply with any accounting principles in preparing its financial statements — the International Financial Reporting Standards; “preference shares”, in relation to a company, means only preference shares that are accounted for as equity by the company under the applicable accounting principles.”;(f)in subsection (28), in the subsection heading, replace “and 92J” with “, 92J and 92L”;(g)in subsection (28A), after “Section 92J”, insert “or 92L”;(h)in subsection (28A), after “section 92J(7)”, insert “or 92L(7) (as the case may be)”; and(i)in subsection (28A)(b), in the definition of “local employee”, in paragraph (b), after “2023”, insert “(for the purposes of section 92J) or 2024 (for the purposes of section 92L)”.

“(18A) Section 13W(1A) applies for the purpose of determining the exempt income of a company (including a non‑umbrella VCC but excluding an umbrella VCC) from the disposal of shares in a VCC (whether or not an umbrella VCC) (called X) with the following modifications:(a)all references to preference shares in X are omitted;(b)the reference in section 13W(1A)(b)(ii) to the paid‑up share capital of ordinary shares and preference shares in X is to the paid‑up share capital of ordinary shares in X.”;

“(20A) For the purposes of subsection (17A) —

“applicable accounting principles”, in relation to a company, means —(a)the accounting principles adopted by the company; or(b)if the company is not required to comply with any accounting principles in preparing its financial statements — the International Financial Reporting Standards;

“preference shares”, in relation to a company, means only preference shares that are accounted for as equity by the company under the applicable accounting principles.”;

In the ITA, in the Third Schedule, in Part 1 —(a)in the Part heading, after “ORDINARY SHARES”, insert “OR PREFERENCE SHARES (OR BOTH)”;(b)in section 13W, in the section heading, after “ordinary shares”, insert “or preference shares”;(c)in section 13W(1), replace “the divesting VCC” wherever it appears with “divesting VCC 1”;(d)in section 13W(1)(a), replace “2027” with “2025”;(e)in section 13W, after subsection (1), insert —“(1A) There is exempt from tax any gains or profits derived by an umbrella VCC (called in this section divesting VCC 2) for the purpose of a sub‑fund from the disposal of ordinary shares or preference shares (or both) in a company (called in this section company Y) or of ordinary shares in a VCC (called in this section VCC Y) that are legally and beneficially owned by divesting VCC 2 for the purpose of that sub‑fund immediately before the disposal, if —(a)the disposal is made on or after 1 January 2026; and(b)the disposal is made after divesting VCC 2 has, at all times during a continuous period of at least 24 months ending on the date immediately before the date of disposal of such shares —(i)legally and beneficially owned (for the purpose of that sub‑fund) at least 20% of the ordinary shares in company Y or VCC Y, as the case may be; or(ii)in the case of company Y only — legally and beneficially owned (for the purpose of that sub‑fund) ordinary shares or preference shares (or both) in company Y the value of which is at least 20% of the total amount of paid‑up share capital of ordinary shares and preference shares in company Y under the applicable accounting principles.”;(f)in section 13W(2), after “Subsection (1)”, insert “or (1A)”;(g)in the following provisions, replace “the divesting VCC” wherever it appears with “divesting VCC 1 or 2”:Section 13W(2)Section 13W(3)Section 13W(7)(a);(h)in the following provisions, after “subsection (1)”, insert “or (1A)”:Section 13W(3)Section 13W(5)(a)Section 13W(7)(a);(i)in section 13W, replace subsection (4) with —“(4) For the purposes of subsection (1) or (1A), divesting VCC 1 or 2 remains the legal and beneficial owner of any shares in another entity (Y) for the purpose of the sub‑fund mentioned in that subsection during the borrowing period when the legal interest in shares had been transferred by divesting VCC 1 or 2 (as the case may be) to another person under a securities lending or repurchase arrangement.”;(j)in section 13W(5)(a), replace “company X or VCC X by the divesting VCC” with “company X or Y or VCC X or Y by divesting VCC 1 or 2”; (k)in section 13W(9), after the definition of “activity of holding immovable properties”, insert —“ “applicable accounting principles”, in relation to a company, means —(a)the accounting principles adopted by the company; or(b)if the company is not required to comply with any accounting principles in preparing its financial statements — the International Financial Reporting Standards;”; and(l)in section 13W(9), after the definition of “ordinary share”, insert —“ “preference shares” means only preference shares that are accounted for as equity by the company concerned under the applicable accounting principles;”.

In the ITA, in the Fourth Schedule, after “14E,”, insert “14EB,”.

—(1) In the ITA, in section 43E, after subsection (3), insert —“(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.(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.”.(2) In the ITA, in section 43I, after subsection (3), insert —“(4) A reference in subsections (1AA)(d) and (1AC) to an authorised body is, in a case where the notice to substitute the rate of tax applicable to an approved global trading 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.”.(3) In the ITA, in section 43N, after subsection (7), insert —“(8) The reference to an authorised body in subsection (1)(c) is, in a case where the concessionary rate of tax in that provision applicable to an approved aircraft leasing 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.(9) A reference in subsections (1)(d) and (1D) to an authorised body is, in a case where the notice to substitute the concessionary rate of tax applicable to an approved aircraft leasing 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.”.(4) In the ITA, in section 43X —(a)in subsection (5)(a), replace “authorised body” with “person appointed by the Minister”; and(b)after subsection (13), insert —“(14) The reference to an authorised body in subsection (5)(b) is, in a case where the base rate in that provision is specified to an approved company during the period from 17 February 2024 to 11 April 2024 (both dates inclusive), a reference to a person appointed by the Minister.(15) A reference in subsections (5)(c) and (6A) to an authorised body is, in a case where the notice to substitute the base rate applicable to an approved 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.(16) A reference in subsections (5)(d) and (6)(a) to an authorised body is, in a case where the rate increase under subsection (6)(a) is specified to an approved company during the period from 1 January 2024 to 11 April 2024 (both dates inclusive), a reference to a person appointed by the Minister.(17) A reference in subsections (5)(d) and (6)(b) to an authorised body is, in a case where the rate increase under subsection (6)(b) is specified to an approved company during the period from 17 February 2024 to 11 April 2024 (both dates inclusive), a reference to a person appointed by the Minister.”.

In the ITA, in section 43E, after subsection (3), insert —“(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.(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.”.

“(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.

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.”.

In the ITA, in section 43I, after subsection (3), insert —“(4) A reference in subsections (1AA)(d) and (1AC) to an authorised body is, in a case where the notice to substitute the rate of tax applicable to an approved global trading 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.”.

“(4) A reference in subsections (1AA)(d) and (1AC) to an authorised body is, in a case where the notice to substitute the rate of tax applicable to an approved global trading 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.”.

In the ITA, in section 43N, after subsection (7), insert —“(8) The reference to an authorised body in subsection (1)(c) is, in a case where the concessionary rate of tax in that provision applicable to an approved aircraft leasing 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.(9) A reference in subsections (1)(d) and (1D) to an authorised body is, in a case where the notice to substitute the concessionary rate of tax applicable to an approved aircraft leasing 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.”.

“(8) The reference to an authorised body in subsection (1)(c) is, in a case where the concessionary rate of tax in that provision applicable to an approved aircraft leasing 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.

A reference in subsections (1)(d) and (1D) to an authorised body is, in a case where the notice to substitute the concessionary rate of tax applicable to an approved aircraft leasing 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.”.

In the ITA, in section 43X —(a)in subsection (5)(a), replace “authorised body” with “person appointed by the Minister”; and(b)after subsection (13), insert —“(14) The reference to an authorised body in subsection (5)(b) is, in a case where the base rate in that provision is specified to an approved company during the period from 17 February 2024 to 11 April 2024 (both dates inclusive), a reference to a person appointed by the Minister.(15) A reference in subsections (5)(c) and (6A) to an authorised body is, in a case where the notice to substitute the base rate applicable to an approved 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.(16) A reference in subsections (5)(d) and (6)(a) to an authorised body is, in a case where the rate increase under subsection (6)(a) is specified to an approved company during the period from 1 January 2024 to 11 April 2024 (both dates inclusive), a reference to a person appointed by the Minister.(17) A reference in subsections (5)(d) and (6)(b) to an authorised body is, in a case where the rate increase under subsection (6)(b) is specified to an approved company during the period from 17 February 2024 to 11 April 2024 (both dates inclusive), a reference to a person appointed by the Minister.”.

“(14) The reference to an authorised body in subsection (5)(b) is, in a case where the base rate in that provision is specified to an approved company during the period from 17 February 2024 to 11 April 2024 (both dates inclusive), a reference to a person appointed by the Minister.

A reference in subsections (5)(c) and (6A) to an authorised body is, in a case where the notice to substitute the base rate applicable to an approved 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.

A reference in subsections (5)(d) and (6)(a) to an authorised body is, in a case where the rate increase under subsection (6)(a) is specified to an approved company during the period from 1 January 2024 to 11 April 2024 (both dates inclusive), a reference to a person appointed by the Minister.

A reference in subsections (5)(d) and (6)(b) to an authorised body is, in a case where the rate increase under subsection (6)(b) is specified to an approved company during the period from 17 February 2024 to 11 April 2024 (both dates inclusive), a reference to a person appointed by the Minister.”.

—(1) In the ITA, in section 13, after subsection (17), insert —“(17A) Regulations made to prescribe the conditions for the exemption from tax under subsection (1)(a), (aa), (ab) and (ba) of income derived from qualifying debt securities that are issued between 1 January 2024 and 31 December 2028 (both dates inclusive), that are made in connection with the amendments made by section 7(a) of the Income Tax (Amendment) Act 2023, may be made to take effect from (and including) 1 January 2024.(17B) Regulations made to amend any regulations made for the purposes of subsection (1)(ba) to replace the terms “break cost” and “prepayment fee” with the term “early redemption fee”, that are made in connection with section 7(b), (g), (h) and (t) of the Income Tax (Amendment) Act 2023, may be made to take effect from (and including) 15 February 2023. (17C) Regulations made to prescribe the arrangements in paragraph (b) of the definition of “qualifying debt securities” in subsection (16), that are made in connection with the amendment to that definition by section 7(i) of the Income Tax (Amendment) Act 2023, may be made to take effect from (and including) 1 January 2024.(17D) Regulations made to prescribe the arrangements in paragraphs (b) and (c) of the definitions of “qualifying debt securities” in subsection (16), that are made in connection with the amendments to that definition by section 7(j), (k), (l), (m) and (n) of the Income Tax (Amendment) Act 2023, may be made to take effect from (and including) 15 February 2023.(17E) Regulations made to prescribe the arrangements in paragraph (a) of the definition of “qualifying project debt securities” in subsection (16), that are made in connection with the amendments to that definition by section 7(p), (q), (r) and (s) of the Income Tax (Amendment) Act 2023, may be made to take effect from (and including) 15 February 2023.”.(2) In the ITA, in section 43H, after subsection (3), insert —“(3AA) Regulations made under subsection (1) —(a)to provide that tax at the rate of 10% is to be levied and paid on income mentioned in that subsection that is derived from any qualifying debt securities issued between 1 January 2024 and 31 December 2028 (both dates inclusive); and (b)to provide for exemption from tax of income derived by a primary dealer from trading in any Singapore Government securities between 1 January 2024 and 31 December 2028 (both dates inclusive),that are made in connection with the amendments to subsections (1)(aa), (ab) and (ac) and (3) by section 36(a) of the Income Tax (Amendment) Act 2023, may be made to take effect from (and including) 1 January 2024.(3AB) Regulations made to amend any regulations made for the purposes of subsection (1) to replace the terms “break cost” and “prepayment fee” with the term “early redemption fee”, that are made in connection with section 36(b), (c) and (d) of the Income Tax (Amendment) Act 2023, may be made to take effect from (and including) 15 February 2023.”.(3) In the ITA, in section 45A —(a)after subsection (2A), insert —“(2AA) Regulations made to impose conditions under subsection (2A) for the disapplication of subsection (1) to any amount payable from Islamic debt securities issued between 1 January 2024 and 31 December 2028 (both dates inclusive), that are made in connection with the amendments made to subsection (2A) by section 41(a) of the Income Tax (Amendment) Act 2023, may be made to take effect from (and including) 1 January 2024.”; and(b)after subsection (2B), insert —“(2BA) Regulations made to amend any regulations made for the purposes of subsection (2B) to replace the terms “break cost” and “prepayment fee” with the term “early redemption fee”, that are made in connection with section 41(b) and (c) of the Income Tax (Amendment) Act 2023, may be made to take effect from (and including) 15 February 2023.”.(4) Section 45(1) of the ITA (including that provision as applied by section 45A of that Act) does not apply to impose any obligation on a person to deduct from any income payable to another person not known to the firstmentioned person to be resident in Singapore, the tax or additional tax chargeable on such income which, but for any regulations made for the purposes of sections 13(1) and 45A(2A) of that Act being given retrospective effect in reliance on sections 13(17A) and 45A(2AA) of that Act (as inserted by this section), would not have been so chargeable.

In the ITA, in section 13, after subsection (17), insert —“(17A) Regulations made to prescribe the conditions for the exemption from tax under subsection (1)(a), (aa), (ab) and (ba) of income derived from qualifying debt securities that are issued between 1 January 2024 and 31 December 2028 (both dates inclusive), that are made in connection with the amendments made by section 7(a) of the Income Tax (Amendment) Act 2023, may be made to take effect from (and including) 1 January 2024.(17B) Regulations made to amend any regulations made for the purposes of subsection (1)(ba) to replace the terms “break cost” and “prepayment fee” with the term “early redemption fee”, that are made in connection with section 7(b), (g), (h) and (t) of the Income Tax (Amendment) Act 2023, may be made to take effect from (and including) 15 February 2023. (17C) Regulations made to prescribe the arrangements in paragraph (b) of the definition of “qualifying debt securities” in subsection (16), that are made in connection with the amendment to that definition by section 7(i) of the Income Tax (Amendment) Act 2023, may be made to take effect from (and including) 1 January 2024.(17D) Regulations made to prescribe the arrangements in paragraphs (b) and (c) of the definitions of “qualifying debt securities” in subsection (16), that are made in connection with the amendments to that definition by section 7(j), (k), (l), (m) and (n) of the Income Tax (Amendment) Act 2023, may be made to take effect from (and including) 15 February 2023.(17E) Regulations made to prescribe the arrangements in paragraph (a) of the definition of “qualifying project debt securities” in subsection (16), that are made in connection with the amendments to that definition by section 7(p), (q), (r) and (s) of the Income Tax (Amendment) Act 2023, may be made to take effect from (and including) 15 February 2023.”.

“(17A) Regulations made to prescribe the conditions for the exemption from tax under subsection (1)(a), (aa), (ab) and (ba) of income derived from qualifying debt securities that are issued between 1 January 2024 and 31 December 2028 (both dates inclusive), that are made in connection with the amendments made by section 7(a) of the Income Tax (Amendment) Act 2023, may be made to take effect from (and including) 1 January 2024.

Regulations made to amend any regulations made for the purposes of subsection (1)(ba) to replace the terms “break cost” and “prepayment fee” with the term “early redemption fee”, that are made in connection with section 7(b), (g), (h) and (t) of the Income Tax (Amendment) Act 2023, may be made to take effect from (and including) 15 February 2023.

Regulations made to prescribe the arrangements in paragraph (b) of the definition of “qualifying debt securities” in subsection (16), that are made in connection with the amendment to that definition by section 7(i) of the Income Tax (Amendment) Act 2023, may be made to take effect from (and including) 1 January 2024.

Regulations made to prescribe the arrangements in paragraphs (b) and (c) of the definitions of “qualifying debt securities” in subsection (16), that are made in connection with the amendments to that definition by section 7(j), (k), (l), (m) and (n) of the Income Tax (Amendment) Act 2023, may be made to take effect from (and including) 15 February 2023.

Regulations made to prescribe the arrangements in paragraph (a) of the definition of “qualifying project debt securities” in subsection (16), that are made in connection with the amendments to that definition by section 7(p), (q), (r) and (s) of the Income Tax (Amendment) Act 2023, may be made to take effect from (and including) 15 February 2023.”.

In the ITA, in section 43H, after subsection (3), insert —“(3AA) Regulations made under subsection (1) —(a)to provide that tax at the rate of 10% is to be levied and paid on income mentioned in that subsection that is derived from any qualifying debt securities issued between 1 January 2024 and 31 December 2028 (both dates inclusive); and (b)to provide for exemption from tax of income derived by a primary dealer from trading in any Singapore Government securities between 1 January 2024 and 31 December 2028 (both dates inclusive),that are made in connection with the amendments to subsections (1)(aa), (ab) and (ac) and (3) by section 36(a) of the Income Tax (Amendment) Act 2023, may be made to take effect from (and including) 1 January 2024.(3AB) Regulations made to amend any regulations made for the purposes of subsection (1) to replace the terms “break cost” and “prepayment fee” with the term “early redemption fee”, that are made in connection with section 36(b), (c) and (d) of the Income Tax (Amendment) Act 2023, may be made to take effect from (and including) 15 February 2023.”.

“(3AA) Regulations made under subsection (1) —(a)to provide that tax at the rate of 10% is to be levied and paid on income mentioned in that subsection that is derived from any qualifying debt securities issued between 1 January 2024 and 31 December 2028 (both dates inclusive); and (b)to provide for exemption from tax of income derived by a primary dealer from trading in any Singapore Government securities between 1 January 2024 and 31 December 2028 (both dates inclusive),that are made in connection with the amendments to subsections (1)(aa), (ab) and (ac) and (3) by section 36(a) of the Income Tax (Amendment) Act 2023, may be made to take effect from (and including) 1 January 2024.

Regulations made to amend any regulations made for the purposes of subsection (1) to replace the terms “break cost” and “prepayment fee” with the term “early redemption fee”, that are made in connection with section 36(b), (c) and (d) of the Income Tax (Amendment) Act 2023, may be made to take effect from (and including) 15 February 2023.”.

In the ITA, in section 45A —(a)after subsection (2A), insert —“(2AA) Regulations made to impose conditions under subsection (2A) for the disapplication of subsection (1) to any amount payable from Islamic debt securities issued between 1 January 2024 and 31 December 2028 (both dates inclusive), that are made in connection with the amendments made to subsection (2A) by section 41(a) of the Income Tax (Amendment) Act 2023, may be made to take effect from (and including) 1 January 2024.”; and(b)after subsection (2B), insert —“(2BA) Regulations made to amend any regulations made for the purposes of subsection (2B) to replace the terms “break cost” and “prepayment fee” with the term “early redemption fee”, that are made in connection with section 41(b) and (c) of the Income Tax (Amendment) Act 2023, may be made to take effect from (and including) 15 February 2023.”.

“(2AA) Regulations made to impose conditions under subsection (2A) for the disapplication of subsection (1) to any amount payable from Islamic debt securities issued between 1 January 2024 and 31 December 2028 (both dates inclusive), that are made in connection with the amendments made to subsection (2A) by section 41(a) of the Income Tax (Amendment) Act 2023, may be made to take effect from (and including) 1 January 2024.”; and

“(2BA) Regulations made to amend any regulations made for the purposes of subsection (2B) to replace the terms “break cost” and “prepayment fee” with the term “early redemption fee”, that are made in connection with section 41(b) and (c) of the Income Tax (Amendment) Act 2023, may be made to take effect from (and including) 15 February 2023.”.

Section 45(1) of the ITA (including that provision as applied by section 45A of that Act) does not apply to impose any obligation on a person to deduct from any income payable to another person not known to the firstmentioned person to be resident in Singapore, the tax or additional tax chargeable on such income which, but for any regulations made for the purposes of sections 13(1) and 45A(2A) of that Act being given retrospective effect in reliance on sections 13(17A) and 45A(2AA) of that Act (as inserted by this section), would not have been so chargeable.

—(1) In the ITA, in section 13O, after subsection (1), insert —“(1AA) Any condition under subsection (1) that is —(a)prescribed by regulations; or(b)specified by the Minister or an authorised body,for the exemption from tax of any prescribed income of an approved company arising from funds managed in Singapore by a fund manager, or from funds managed by an approved person, that is derived at any time between 1 January 2025 and the date of commencement of section 54(1) of the Finance (Income Taxes) Act 2025 (both dates inclusive), may be made to take effect from (and including) 1 January 2025.”.(2) In the ITA, in section 13OA —(a)after subsection (1), insert —“(1A) Any condition under subsection (1) that is —(a)prescribed by regulations; or(b)specified by the Minister or an authorised body,for the exemption from tax of any prescribed income of a partner of an approved limited partnership arising from funds managed in Singapore by a fund manager, or from funds managed by an approved person, that is derived at any time between 1 January 2025 and the date of commencement of section 54(2) of the Finance (Income Taxes) Act 2025 (both dates inclusive), may be made to take effect from (and including) 1 January 2025.”; and(b)after subsection (13), insert —“(13A) Any regulations to provide for any matter in subsection (13) (except for paragraph (d)) in relation to any income of a partner of an approved limited partnership that is derived at any time between 1 January 2025 and the date of commencement of section 54(2) of the Finance (Income Taxes) Act 2025 (both dates inclusive), may be made to take effect from (and including) 1 January 2025.”.(3) In the ITA, in section 13U, after subsection (2E), insert —“(2EA) Any condition under subsection (1) that is —(a)prescribed by regulations; or(b)specified by the Minister or an authorised body,for the exemption from tax of any prescribed income of a person mentioned in subsection (1)(a) to (d), arising from funds managed in Singapore by a fund manager, that is derived at any time between 1 January 2025 and the date of commencement of section 54(3) of the Finance (Income Taxes) Act 2025 (both dates inclusive), may be made to take effect from (and including) 1 January 2025.”.

In the ITA, in section 13O, after subsection (1), insert —“(1AA) Any condition under subsection (1) that is —(a)prescribed by regulations; or(b)specified by the Minister or an authorised body,for the exemption from tax of any prescribed income of an approved company arising from funds managed in Singapore by a fund manager, or from funds managed by an approved person, that is derived at any time between 1 January 2025 and the date of commencement of section 54(1) of the Finance (Income Taxes) Act 2025 (both dates inclusive), may be made to take effect from (and including) 1 January 2025.”.

“(1AA) Any condition under subsection (1) that is —(a)prescribed by regulations; or(b)specified by the Minister or an authorised body,for the exemption from tax of any prescribed income of an approved company arising from funds managed in Singapore by a fund manager, or from funds managed by an approved person, that is derived at any time between 1 January 2025 and the date of commencement of section 54(1) of the Finance (Income Taxes) Act 2025 (both dates inclusive), may be made to take effect from (and including) 1 January 2025.”.

In the ITA, in section 13OA —(a)after subsection (1), insert —“(1A) Any condition under subsection (1) that is —(a)prescribed by regulations; or(b)specified by the Minister or an authorised body,for the exemption from tax of any prescribed income of a partner of an approved limited partnership arising from funds managed in Singapore by a fund manager, or from funds managed by an approved person, that is derived at any time between 1 January 2025 and the date of commencement of section 54(2) of the Finance (Income Taxes) Act 2025 (both dates inclusive), may be made to take effect from (and including) 1 January 2025.”; and(b)after subsection (13), insert —“(13A) Any regulations to provide for any matter in subsection (13) (except for paragraph (d)) in relation to any income of a partner of an approved limited partnership that is derived at any time between 1 January 2025 and the date of commencement of section 54(2) of the Finance (Income Taxes) Act 2025 (both dates inclusive), may be made to take effect from (and including) 1 January 2025.”.

“(1A) Any condition under subsection (1) that is —(a)prescribed by regulations; or(b)specified by the Minister or an authorised body,for the exemption from tax of any prescribed income of a partner of an approved limited partnership arising from funds managed in Singapore by a fund manager, or from funds managed by an approved person, that is derived at any time between 1 January 2025 and the date of commencement of section 54(2) of the Finance (Income Taxes) Act 2025 (both dates inclusive), may be made to take effect from (and including) 1 January 2025.”; and

“(13A) Any regulations to provide for any matter in subsection (13) (except for paragraph (d)) in relation to any income of a partner of an approved limited partnership that is derived at any time between 1 January 2025 and the date of commencement of section 54(2) of the Finance (Income Taxes) Act 2025 (both dates inclusive), may be made to take effect from (and including) 1 January 2025.”.

In the ITA, in section 13U, after subsection (2E), insert —“(2EA) Any condition under subsection (1) that is —(a)prescribed by regulations; or(b)specified by the Minister or an authorised body,for the exemption from tax of any prescribed income of a person mentioned in subsection (1)(a) to (d), arising from funds managed in Singapore by a fund manager, that is derived at any time between 1 January 2025 and the date of commencement of section 54(3) of the Finance (Income Taxes) Act 2025 (both dates inclusive), may be made to take effect from (and including) 1 January 2025.”.

“(2EA) Any condition under subsection (1) that is —(a)prescribed by regulations; or(b)specified by the Minister or an authorised body,for the exemption from tax of any prescribed income of a person mentioned in subsection (1)(a) to (d), arising from funds managed in Singapore by a fund manager, that is derived at any time between 1 January 2025 and the date of commencement of section 54(3) of the Finance (Income Taxes) Act 2025 (both dates inclusive), may be made to take effect from (and including) 1 January 2025.”.

—(1) There is to be remitted the tax payable for the year of assessment 2025 by an individual resident in Singapore an amount equal to the lower of the following:(a)60% of the tax payable by that individual for that year of assessment;(b)$200.(2) The amount of such remission is to be determined by the Comptroller.

There is to be remitted the tax payable for the year of assessment 2025 by an individual resident in Singapore an amount equal to the lower of the following:(a)60% of the tax payable by that individual for that year of assessment;(b)$200.

The amount of such remission is to be determined by the Comptroller.