The chargeable or exempt income of an umbrella VCC is the total sum of the chargeable or exempt income of its sub funds. The income of a sub-fund is determined as if it were a VCC and the tax rules are applied at the sub-fund level. Tax credits, if any, are also computed at the sub-fund level.
• Certain common tax rules are applied separately at the umbrella and sub-fund levels:
• Unabsorbed capital allowances, losses and donations — sub-fund level.
• Shareholding test — sub-fund level.
• Partial tax exemption, start-up tax exemption and corporate tax rebate — VCC level.
• Exemption of gains or profits from disposal of ordinary shares — sub-fund level.
• Modification of provisions for VCCs redomiciled in Singapore — sub-fund level.
• Tax credits — sub-fund level.