Income Tax (Exemption of Interest and Other Payments for Economic and Technological Development Loans) (Consolidation) Notification

Income Tax Act

(CHAPTER 134, Section 13(4))

N 8

REVISED EDITION 1996

(15th May 1996)

1.—(1) Any fee or compensatory payment made by an Asian Currency Unit of a financial institution or by an approved securities company to —

(a)	a person who is neither a resident of nor a permanent establishment in Singapore; or
(b)	a branch office outside Singapore of a bank resident in Singapore which has an Asian Currency Unit,

in respect of any loan of designated securities under a securities lending arrangement in writing shall be exempt from tax.

(2) For the purposes of sub-paragraph (1) —

“approved securities company” means a company approved under section 43A(1)(c) of the Act;

“compensatory payment” means a payment in lieu of any interest, dividend or right to purchase warrants, options or additional securities which a lender in a securities lending arrangement would have received in respect of the designated securities relating to such arrangement had it not been for such arrangement;

“designated securities” means —

(a)	stocks, shares, bonds and other securities, denominated in any foreign currency, issued by a company which is not incorporated in Singapore and which is not resident in Singapore; or
(b)	bonds denominated in any foreign currency issued by any foreign government. [S 58/95] [1.4.94]

2.—(1) The interest payable by the Petrochemical Corporation of Singapore (Private) Limited under the Multicurrency Facility Agreement dated 20th September 1994 shall be exempt from withholding tax from 20th September 1994 to 30th June 2004.

(2) The commitment, agency and front-end/arrangers’ fees payable by the Petrochemical Corporation of Singapore (Private) Limited in connection with the loan shall also be exempt from withholding tax.

[S 155/95]

[31.3.95]

3.—(1) The interest payable by the Polyolefin Company (Singapore) Pte Ltd under the Multicurrency Facility Agreement dated 20th September 1994 shall be exempt from withholding tax from 20th September 1994 to 30th June 2004.

(2) The commitment, agency and front-end/arrangers’ fees payable by the Polyolefin Company (Singapore) Pte Ltd in connection with the loan shall also be exempt from withholding tax.

[S 156/95]

[31.3.95]

4.—(1) There shall be exempt from tax interest received from notes issued under the US$300 million Asian Dragon Medium Term Note Programme of Asian Finance and Investment Corporation Ltd by —

(a)	any non-resident individual; and
(b)	any person, other than an individual, if that person is neither a resident of nor a permanent establishment in Singapore.

(2) The exemption is subject to the terms and conditions specified in the Ministry of Finance’s letter of approval dated 7th June 1995.

[S 297/95]

[7.7.95]

5. The interest payable by Powick Marine (S) Pte Ltd to ORIX Asia Limited, Hong Kong, under the Loan Agreement dated 2nd March 1995 shall be exempt from income tax from 2nd March 1995 to 31st July 2005.

[S 356/95]

[18.8.95]

6. The interest payable by Singapore Petroleum Company Limited to Vilexton Pty Limited, Australia, under the Facility Agreement dated 24th August 1995 shall be exempt from income tax from 24th August 1995 to 30th September 2000.

[S 405/95]

[8.9.95]

7. The interest and swap payment payable by Singapore Aromatics Company Private on the loan amount of US$275 million under the Loan Agreement dated 30th May 1995 shall be exempt from withholding tax from 30th May 1995 to 15th September 2007.

[S 465/95]

[20.10.95]

8. The interest and swap payment payable by W & T Logistics Pte Limited under the Loan Agreement dated 21st June 1995 shall be exempt from withholding tax from 21st June 1995 to 7th September 2000.

[S 466/95]

[20.10.95]

9. The interest and swap payment payable by Far East Levingston Shipbuilding Limited under the Loan Agreement dated 21st June 1995 shall be exempt from withholding tax from 21st June 1995 to 7th September 2000.

[S 467/95]

[20.10.95]

10. The interest payable by Masterbulk Private Limited to Westfal-Larsen & Co. A/S, Norway on the loan of US$96,630,099 under the Loan Agreement dated 23rd June 1995 as amended by the Agreement dated 26th October 1995 shall be exempt from income tax from 23rd June 1995 to 1st July 2010.

[S 550/95]

[15.12.95]

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