What happened
On 6 July 2026, MOF gazetted the Income Tax (Exemption of Income of Foreign Trusts) (Amendment) Regulations 2026 (S 488/2026). The principal regulations, made under section 13F of the Income Tax Act, exempt "specified income" of qualifying foreign trusts administered by Singapore trust companies. The amendments are retrospective and bring this definition into line with the expanded income lists in the fund-management exemption regulations:
- from 19 February 2019, with a new period from 19 February 2019 to 8 March 2020, including certain Singapore-sourced income paid out of a foreign LLC that has borne Singapore tax
- from 19 February 2022, by reference to Part B of the Fifth Schedule of the 2010 fund regulations
Why it matters
Before these changes, the scope of the foreign trust exemption lagged behind the fund exemption schemes. That left trustees uncertain about income earned in periods where the two regimes differed. Backdating the amendments to the dates the fund lists were widened means the trust regime may now cover income that previously fell outside it. That affects private trust companies, licensed trustees and the families they serve.
What to do now
Trustees of foreign trusts administered in Singapore should review returns and positions from 2019 onwards. Look for income now covered by the exemption, and consider whether earlier assessments can be revised within the statutory time limits. Families should also check the trust's investment mandate against the current specified-income lists before taking on new asset classes.
Key resources
General information only; not tax or legal advice.
