No. S 615
Income Tax Act 1947
Income Tax
(Cromwell SG SPV 5 Pte. Ltd. —
Section 13(12) Exemption) Order 2022
In exercise of the powers conferred by section 13(12) of the Income Tax Act 1947, the Minister for Finance makes the following Order:
Citation
1.  This Order is the Income Tax (Cromwell SG SPV 5 Pte. Ltd. — Section 13(12) Exemption) Order 2022.
Exemption
2.—(1)  Dividend income described in sub‑paragraph (2), that is received in Singapore by Cromwell SG SPV 5 Pte. Ltd. on or after 17 February 2022 from Cromwell EREIT Lux 5 S.a r.l. (a company incorporated in Luxembourg), is exempt from tax.
(2)  Sub‑paragraph (1) applies to dividend income paid out of distribution income received by Cromwell EREIT Lux 5 S.a r.l. from Cromwell Europa 1 and Cromwell Europa 2 (being real estate investment funds constituted in Italy), which is in turn paid out of —
(a)any rental and property‑related income (including capital gains) of Cromwell Europa 1 and Cromwell Europa 2 from the specified property; and
(b)any interest income derived from any deposit with a financial institution of such rental and property‑related income.
(3)  The exemption in sub‑paragraph (1) is subject to the conditions specified in the letter of approval dated 17 February 2022 addressed to EY Corporate Advisors Pte. Ltd.
(4)  In sub‑paragraph (2), “specified property” means the property named “Centro Logistico Orlando Marconi” located at Via del Lavoro, Monteprandone, Italy.
Made on 23 July 2022.
LAI WEI LIN
Second Permanent Secretary,
Ministry of Finance,
Singapore.
[AG/LEGIS/SL/134/2020/23 Vol. 3]