| (a) | in sub-paragraph (1), replace “Subject to sub‑paragraph (3)” with “Subject to sub‑paragraphs (3) and (4)”; |
| (b) | in sub‑paragraphs (1) and (2), replace “who is neither resident in Singapore nor a permanent establishment in Singapore” with “referred to in sub‑paragraph (6)”; |
| (c) | in sub-paragraph (1), replace sub‑paragraphs (a), (aa) and (b) with —| “(a) | a bank; | | (b) | a merchant bank; or | | (c) | a finance company,”; |
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| (d) | in sub-paragraph (1)(iii)(B), delete “or” at the end; |
| (e) | in sub-paragraph (1), after sub‑paragraph (iii), insert —| “(iiia) | is liable to be made —| (A) | under a contract which is varied, where the variation takes effect on a date which falls within the period from 4 November 2022 to 31 December 2026 (both dates inclusive); and | | (B) | on or after the date on which the variation takes effect; or”; |
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| (f) | in sub-paragraph (2), replace “Subject to sub‑paragraph (3)” with “Subject to sub‑paragraphs (3) and (5)”; |
| (g) | in sub-paragraph (2)(a), replace “securities” with “capital markets products”; |
| (h) | in sub-paragraph (2)(i)(B), delete “or” at the end; |
| (i) | in sub-paragraph (2)(i), after sub‑paragraph (B), insert —| “(BA) | a contract which is varied, where the variation took effect before the approval date, being a date that is on or after 4 November 2022; or”; |
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| (j) | in sub-paragraph (2)(iii)(B), delete “or” at the end; |
| (k) | in sub-paragraph (2), after sub‑paragraph (iii), insert — | “(iiia) | is liable to be made — | (A) | under a contract which is varied, where the variation takes effect on a date which falls within the period from 4 November 2022 or the approval date (whichever is later) to 31 December 2026 (both dates inclusive); and | | (B) | on or after the date on which the variation takes effect; or”; |
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| (l) | in sub‑paragraph (3), replace “person” with “bank, merchant bank, finance company”; and |
| (m) | after sub‑paragraph (3), insert — “(4) Sub‑paragraph (1) does not apply to any qualifying payment liable to be made — | (a) | under a contract mentioned in sub‑paragraph (1)(ii), (iii) or (iiia), that is varied with effect from a date on or after 1 January 2027; and | | (b) | on or after the date on which such variation takes effect. |
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(5) Sub-paragraph (2) does not apply to any qualifying payment liable to be made —| (a) | under a contract mentioned in sub‑paragraph (2)(ii), (iii) or (iiia), that is varied with effect from a date on or after 1 January 2027; and | | (b) | on or after the date on which such variation takes effect. |
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(6) The person referred to in sub‑paragraphs (1) and (2), to whom the qualifying payment is made, is — | (a) | a person who is not resident in Singapore and who does not have a permanent establishment in Singapore; or | | (b) | a person who is not resident in Singapore and who carries on any operation in Singapore through a permanent establishment in Singapore, where —| (i) | the contract under which the qualifying payment is made is not entered into through that operation; or | | (ii) | the debt security under which the qualifying payment is made is not acquired by that person through that operation.”. |
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