An operating company with substantive presence in Singapore generally has the following characteristics: 

• Is a business entity that is registered in Singapore; 
• Has at least 25% local shareholding interest; 
• Has a minimum of 3 employees in Singapore; and 
• Has an operating premise in Singapore. 

Entities that are involved in the business of trading or holding of Singapore immovable properties (other than one that is in the business of property development) do not qualify as investments under Option 3 of the CDR. 

For cases such as (b) and (c), the SFO fund must be able to demonstrate in its records that the definitions above are fulfilled for the underlying non-listed Singapore-incorporated operating company.

An indirect holding in a non-listed Singapore-incorporated operating company through a holding company will be considered as fulfilling Option 3 of the CDR, provided the following conditions are met: 

• The intermediate entities in the ownership chain are purely investment holding structures or special purpose vehicles (SPVs) with no independent business operations of their own; and 
• The underlying operating company is a non-listed Singapore-incorporated company with substantive business operations and a substantive presence in Singapore.