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| The interest payable by A.P. Moller Singapore Pte. Ltd. to Hyundai Heavy Industries Co. Ltd., Republic of Korea and any of its assigns which is not resident in Singapore under the following promissory notes shall, subject to the terms and conditions specified in the letters of approval dated 10th April 1989 and 18th August 1989 addressed to A.P. Moller Singapore Pte. Ltd., be exempt from income tax: |
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| (a) Note No. I-1 to 13 and II-1 to 6 dated 16th October 1989; |
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| (b) Note No. I-1 to 13 and II-1 to 6 dated 15th December 1989; |
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| (c) Note No. I-1 to 10 and II-1 to 6 dated 9th April 1990; |
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| (d) Note No. I-1 to 10 and II-1 to 6 dated 17th April 1990; |
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| (e) Note No. I-1 to 10 and II-1 to 6 dated 27th April 1990; and |
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| (f) Note No. I-1 to 10 and II-1 to 6 dated 4th September 1990. |
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| The swap payments payable by Singapore Aerospace Manufacturing Pte. Ltd. to The Development Bank of Singapore Limited, Tokyo Branch under the Interest Rate Swap Agreement dated 1st August 1991 shall be exempt from income tax. |
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| 2. The management fee of US$43,750 payable by Singapore Aerospace Manufacturing Pte. Ltd. to Tokyo Leasing Co., Ltd., Japan under the Credit Sale Agreement dated 1st August 1991 shall be exempt from income tax. |
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| The royalties payable by Lotus Development B.V. Asia Pacific Branch to Lotus Development Corporation USA for the right to use the technology to manufacture the software products of Lotus in Singapore under the Royalty Agreement dated 1st April 1985 shall be exempt from income tax. |
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| Subject to paragraph 2, where any payment under an interest rate swap or currency swap transaction is made by an Asian Currency Unit of a financial institution in Singapore — |
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| (a) in currencies other than Singapore dollars; and |
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| (b) to a person not resident in Singapore, other than a permanent establishment in Singapore, |
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| that payment shall be exempt from tax. |
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| 2.—(1) Paragraph 1 shall not apply to an interest rate swap or currency swap transaction where the parties thereto are related to one another unless the transaction is approved by the Minister or such other person as he may appoint. |
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| (2) For the purposes of sub-paragraph (1), a person shall be deemed to be related to another where one person, whether directly or indirectly, has the ability to control the other or where both of them, whether directly or indirectly, are under the control of a common person. |
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| There shall be exempt from tax discount received from any of the Swiss Francs 70,000,000 Zero Coupon Notes due 1992 issued by Commonwealth Bank of Australia, Singapore on 8th October 1985 by — |
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| (a) any non-resident individuals; and |
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| (b) any person, other than an individual, if that person is neither a resident of nor a permanent establishment in Singapore. |
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