Income Tax (Steppe Capital Pte Ltd — Section 13(12) Exemption) Order 2022

Citation

1. This Order is the Income Tax (Steppe Capital Pte Ltd — Section 13(12) Exemption) Order 2022.

Definitions

2. In this Order —

“Co-operative” means Steppe Unity Cooperatief U.A. incorporated in the Netherlands;

“Holding Company” means any of the following companies incorporated in the Netherlands:

(a)	KazStroyService Infrastructure B.V.;
(b)	Venus Airport Holdings B.V.;
(c)	Aquila Properties Holdings B.V.;
(d)	Asset Estate Holdings B.V.

Exemption for income received between 5 December 2011 and 6 August 2013

3.—(1) The income received in Singapore by Steppe Capital Pte Ltd, comprising distributions from the Co‑operative or dividends from any Holding Company, is exempt from tax if the income is —

(a)	so received between 5 December 2011 and 6 August 2013 (both dates inclusive); and
(b)	derived by Steppe Capital Pte Ltd through the holding structures described in the letter dated 4 July 2012 from the tax agent of Steppe Capital Pte Ltd to the Inland Revenue Authority of Singapore (as amended by the electronic message of 4 September 2012 from the tax agent).

(2) The exemption in sub‑paragraph (1) does not apply to any distribution or dividend declared out of the income of the Co‑operative or Holding Company (as the case may be) that is directly or indirectly derived from an ultimate entity.

(3) For the purposes of sub‑paragraph (2), the income of an entity (A) is indirectly derived from another entity (B) if the income of A is derived from another entity whose income is in turn directly or indirectly derived (including by one or more applications of this sub‑paragraph) from B.

(4) The exemption in sub‑paragraph (1) is subject to the terms and conditions specified in paragraphs 4 and 5 of the letter of approval dated 25 February 2013 addressed to the tax agent of Steppe Capital Pte Ltd.

(5) In this paragraph, “ultimate entity” means an entity that is set out in the First Schedule.

Exemption for income received between 7 August 2013 and 2 February 2015

4.—(1) The income received in Singapore by Steppe Capital Pte Ltd, comprising distributions from the Co‑operative or dividends from any Holding Company, is exempt from tax if the income is —

(a)	so received between 7 August 2013 and 2 February 2015 (both dates inclusive); and
(b)	derived by Steppe Capital Pte Ltd through the holding structures described in the letter of approval dated 14 May 2014 addressed to Steppe Capital Pte Ltd.

(2) The exemption in sub‑paragraph (1) does not apply to any distribution or dividend declared out of the income of the Co‑operative or Holding Company (as the case may be) that is directly or indirectly derived from an ultimate entity.

(3) For the purposes of sub‑paragraph (2), the income of an entity (A) is indirectly derived from another entity (B) if the income of A is derived from another entity whose income is in turn directly or indirectly derived (including by one or more applications of this sub‑paragraph) from B.

(4) The exemption in sub‑paragraph (1) is subject to the terms and conditions specified in paragraphs 4 and 5 of the letter of approval dated 25 February 2013 addressed to the tax agent of Steppe Capital Pte Ltd, which are incorporated by reference in paragraph 6 of the letter of approval dated 14 May 2014 addressed to Steppe Capital Pte Ltd.

(5) In this paragraph, “ultimate entity” means an entity that is set out in the Second Schedule.

Exemption for income received between 3 February 2015 and 2 August 2017

5.—(1) The income received in Singapore by Steppe Capital Pte Ltd, comprising distributions from the Co‑operative or dividends from any Holding Company, is exempt from tax if the income is —

(a)	so received between 3 February 2015 and 2 August 2017 (both dates inclusive); and
(b)	derived by Steppe Capital Pte Ltd through the holding structures described in the letter of approval dated 2 March 2016 addressed to Steppe Capital Pte Ltd.

(2) The exemption in sub‑paragraph (1) does not apply to any distribution or dividend declared out of the income of the Co‑operative or Holding Company (as the case may be) that is directly or indirectly derived from an ultimate entity.

(3) For the purposes of sub-paragraph (2), the income of an entity (A) is indirectly derived from another entity (B) if the income of A is derived from another entity whose income is in turn directly or indirectly derived (including by one or more applications of this sub‑paragraph) from B.

(4) The exemption in sub‑paragraph (1) is subject to the terms and conditions specified in —

(a)	paragraph 9 of the letter of approval dated 2 March 2016 addressed to Steppe Capital Pte Ltd; and
(b)	paragraphs 4 and 5 of the letter of approval dated 25 February 2013 addressed to the tax agent of Steppe Capital Pte Ltd, which are incorporated by reference in paragraph 10 of the letter of approval dated 2 March 2016 addressed to Steppe Capital Pte Ltd.

(5) In this paragraph, “ultimate entity” means an entity that is set out in the Third Schedule.

Exemption for income received between 3 August 2017 and 19 November 2017

6.—(1) The income received in Singapore by Steppe Capital Pte Ltd, comprising distributions from the Co-operative or dividends from any Holding Company, is exempt from tax if the income is —

(a)	so received between 3 August 2017 and 19 November 2017 (both dates inclusive); and
(b)	derived by Steppe Capital Pte Ltd through the holding structures described in the letter of approval dated 3 August 2018 addressed to Steppe Capital Pte Ltd.

(2) The exemption in sub‑paragraph (1) does not apply to any distribution or dividend declared out of the income of the Co‑operative or Holding Company (as the case may be) that is directly or indirectly derived from an ultimate entity.

(3) For the purposes of sub‑paragraph (2), the income of an entity (A) is indirectly derived from another entity (B) if the income of A is derived from another entity whose income is in turn directly or indirectly derived (including by one or more applications of this sub‑paragraph) from B.

(4) The exemption in sub‑paragraph (1) is subject to the terms and conditions specified in paragraphs 6 and 7 of the letter of approval dated 3 August 2018 addressed to Steppe Capital Pte Ltd.

(5) In this paragraph, “ultimate entity” means an entity that is set out in the Fourth Schedule.

Exemption for income received on or after 20 November 2017

7.—(1) The income received in Singapore by Steppe Capital Pte Ltd, comprising distributions from the Co‑operative or dividends from any Holding Company, is exempt from tax if the income is —

(a)	so received on or after 20 November 2017; and
(b)	derived by Steppe Capital Pte Ltd through the holding structures described in the letter of approval dated 3 December 2020 addressed to Steppe Capital Pte Ltd.

(2) The exemption in sub‑paragraph (1) does not apply to any distribution or dividend declared out of the income of the Co‑operative or Holding Company (as the case may be) that is directly or indirectly derived from an ultimate entity.

(3) For the purposes of sub‑paragraph (2), the income of an entity (A) is indirectly derived from another entity (B) if the income of A is derived from another entity whose income is in turn directly or indirectly derived (including by one or more applications of this sub‑paragraph) from B.

(4) The exemption in sub‑paragraph (1) is subject to the terms and conditions specified in paragraphs 5 and 6 of the letter of approval dated 3 December 2020 addressed to Steppe Capital Pte Ltd.

(5) In this paragraph, “ultimate entity” means an entity that is set out in the Fifth Schedule.

Revocation

8. The Income Tax (Exemption of Foreign Income) (No. 6) Order 2013 (G.N. No. S 404/2013) is revoked.

Search within Legislation