Statute Details
- Title: Residential Property (GLG International Investments Pte. Ltd. — Exemption) Notification 2021
- Act Code: RPA1976-S722-2021
- Legislation Type: Subsidiary Legislation (SL)
- Authorising Act: Residential Property Act (Chapter 274)
- Enacting Authority: Minister for Law (made by the Permanent Secretary, Ministry of Law)
- Notification Number: No. S 722
- Commencement: 27 September 2021
- Current Version Status: Current version as at 27 Mar 2026 (per the legislation portal)
- Key Provisions: Exemptions from approvals under Sections 9, 28, 28A, and 31 of the Residential Property Act; conditions in the Schedule
What Is This Legislation About?
The Residential Property (GLG International Investments Pte. Ltd. — Exemption) Notification 2021 is a targeted exemption instrument issued under the Residential Property Act (the “RPA”). In plain terms, it allows a specific company—GLG International Investments Pte. Ltd. (“the relevant company”)—to carry out certain residential property-related transactions and development plans without obtaining particular approvals that would otherwise be required under the RPA.
Singapore’s Residential Property regime generally regulates how residential property may be acquired, converted, and developed, particularly where such activities involve entities that are subject to additional controls (for example, rules relating to “converted entities”, change of use, rezoned land, and housing developer’s approvals). This Notification carves out a narrow set of exemptions for the relevant company, but only for property and purposes that match the Notification’s conditions.
Practically, the Notification is designed to facilitate a development pipeline for the relevant company. It does so by removing approval bottlenecks at key stages: (i) conversion into a “converted entity”, (ii) changing existing use to develop residential property for sale or disposal for profit, (iii) developing rezoned/vacant land intended for residential development for profit, and (iv) obtaining housing developer’s approval—subject to an important carve-out for retention of certain landed houses.
What Are the Key Provisions?
1. Citation and commencement (Section 1)
Section 1 provides the Notification’s short title and commencement date. It comes into operation on 27 September 2021. This date is crucial because the exemptions in later sections are expressly tied to transactions and property that occur “before, on or after 27 September 2021” (or “on or after 27 September 2021”). For practitioners, this means careful document review is needed to confirm the relevant company’s ownership/vesting timing and the intended development purpose.
2. Exemption from need for approval to become converted entity (Section 2)
Section 2 states that Section 9 of the RPA does not apply to the relevant company in relation to any residential property that satisfies three cumulative criteria:
- (a) Not non-restricted residential property: the property must be residential property that is not “non-restricted residential property” (a classification that matters under the RPA framework).
- (b) Vesting immediately before conversion: the property must be vested in the relevant company immediately before its conversion into a “converted entity” before, on or after 27 September 2021.
- (c) Intended development and ultimate purpose of sale/disposal for profit: the property must be intended for development as residential property, with the ultimate purpose that the relevant company will sell or dispose of it as residential property for profit after conversion.
In effect, Section 2 removes the need for the Section 9 approval that would otherwise be required when the company becomes a converted entity, but only for qualifying residential property and only where the development and commercial end-use is sale/disposal for profit.
3. Exemption from need for approval to change existing use (Section 3)
Section 3 provides that Section 28 of the RPA does not apply to the relevant company in relation to land that:
- (a) Is acquired/owned/purchased on or after 27 September 2021; and
- (b) Is intended for change of use to and development as residential property, with the ultimate purpose of sale or disposal by the relevant company as residential property for profit.
This provision is significant because Section 28 approvals typically address regulatory concerns around changing land use to residential development. The exemption is therefore a procedural relief for the relevant company’s development strategy, but it is anchored to the timing of acquisition and the stated commercial purpose.
4. Exemption from need for approval for rezoned land (Section 4)
Section 4 exempts the relevant company from Section 28A of the RPA in relation to vacant land (whether or not there is a vacant/disused building or structure) that:
- (a) Is owned by the relevant company on or after 27 September 2021; and
- (b) Is intended for development as residential property, with the ultimate purpose of sale or disposal by the relevant company as residential property for profit.
For practitioners, the “vacant land” framing is important. It suggests the exemption targets a specific development category—vacant sites—where rezoning/approval processes under Section 28A would otherwise be triggered. The exemption’s scope is limited to the relevant company and to qualifying vacant land intended for residential development for profit.
5. Exemption from need for housing developer’s approval (Section 5)
Section 5 is the most nuanced operational provision. It provides that Section 31 of the RPA does not apply to the relevant company, subject to a key exception.
Under Section 5(1), the general rule is exemption from housing developer’s approval. However, Section 5(2) preserves the applicability of Section 31(1) and (4) in relation to the retention of a dwelling-house that is a landed dwelling-house.
Section 5(3) defines “landed dwelling-house” as a detached house, semi-detached house, or terrace house (including linked house or townhouse), whether or not comprised within a strata title plan registered under the Land Titles (Strata) Act (Cap. 158).
Why this matters: even where the relevant company is exempt from housing developer’s approval, it cannot ignore Section 31 requirements when the development involves retaining a landed dwelling-house. This carve-out indicates that the legislature (or Minister) intended to protect certain landed housing retention outcomes from being fully deregulated.
6. Conditions of exemption (Section 6 and the Schedule)
Section 6 states that the exemptions are subject to the conditions specified in the Schedule. Although the extract provided does not reproduce the Schedule text, the legal effect is clear: the exemptions are not absolute. Practitioners must obtain and review the Schedule conditions to determine compliance requirements, reporting obligations, time limits, or other regulatory constraints.
Because the Schedule is incorporated by reference, failure to satisfy any condition could jeopardise the exemption’s availability. In practice, lawyers should treat the Schedule as essential due diligence material—particularly where transactions are structured over multiple phases (acquisition, conversion, rezoning, development, and sale/disposal).
How Is This Legislation Structured?
The Notification is structured as a short, six-part instrument:
- Section 1: Citation and commencement (27 September 2021).
- Sections 2–5: Four targeted exemptions from specific approval requirements under the Residential Property Act—conversion into a converted entity, change of use, rezoned land/vacant land, and housing developer’s approval (with a landed dwelling-house retention carve-out).
- Section 6: General “subject to conditions” clause, pointing to the Schedule.
- The Schedule: Sets out the conditions that govern the exemptions.
From a drafting and compliance perspective, the Notification follows a common pattern for bespoke exemptions: it identifies the relevant company, specifies the statutory provisions from which it is exempt, and then limits the exemption to defined property categories and intended development purposes, all under conditions in a Schedule.
Who Does This Legislation Apply To?
This Notification applies only to GLG International Investments Pte. Ltd. It does not create a general class exemption for other developers or companies. The exemptions are therefore company-specific and transaction-specific.
Additionally, the exemptions apply only in relation to qualifying property and intended uses. For example, Section 2 is limited to residential property that is not “non-restricted residential property” and that is vested immediately before conversion, with development and ultimate sale/disposal for profit. Sections 3 and 4 similarly require specific timing (acquired/owned on or after 27 September 2021) and the ultimate profit-driven residential development purpose. Section 5’s exemption from housing developer’s approval is also constrained by the landed dwelling-house retention exception.
Why Is This Legislation Important?
For practitioners advising developers, landowners, or corporate restructuring teams, this Notification is important because it can materially affect the regulatory timeline and approval workflow. Exemptions from approvals under the RPA can reduce delays, simplify compliance steps, and influence transaction structuring (e.g., whether conversion, acquisition, or change-of-use steps need to be sequenced around approval requirements).
However, the Notification’s value is paired with legal risk: the exemptions are narrow and conditional. The “ultimate purpose” language (development as residential property with sale/disposal for profit) requires that the intended commercial use be consistent with the development plan and documented evidence. Similarly, the carve-out for retention of landed dwelling-houses means that certain aspects of a project may still require compliance with Section 31(1) and (4).
Finally, because Section 6 makes the exemptions “subject to the conditions specified in the Schedule,” practitioners must treat the Schedule as determinative. In disputes or regulatory reviews, the Schedule conditions are likely to be the first place the authority will look to assess whether the exemption was properly relied upon. Accordingly, counsel should verify the Schedule’s requirements before advising on reliance or closing transactions.
Related Legislation
- Residential Property Act (Chapter 274) — in particular Sections 9, 28, 28A, and 31 (as referenced by this Notification)
- Land Titles (Strata) Act (Cap. 158) — relevant to the definition of “landed dwelling-house” for Section 5(3)
- Residential Property Act timeline / legislation timeline — for confirming the correct version of the RPA and any amendments affecting the referenced sections
Source Documents
This article provides an overview of the Residential Property (GLG International Investments Pte. Ltd. — Exemption) Notification 2021 for legal research and educational purposes. It does not constitute legal advice. Readers should consult the official text for authoritative provisions.