2.—(1) The front‑end fees and interest payable by Grace Ocean Private Limited to The Hiroshima Bank, Ltd in respect of the following amounts under a loan agreement dated 25 March 2011 as amended under the respective supplemental agreements, being a loan made for the purpose of financing the acquisition of the vessel “CS Best”, are exempt from tax:
(a)
USD 4,079,530.82 outstanding as at 9 March 2020 under the loan agreement as amended by supplemental agreements dated 25 August 2015, 18 January 2017 and 9 March 2020;
(b)
JPY 248,140,437 outstanding as at 18 January 2021 under the loan agreement as amended by supplemental agreements dated 25 August 2015, 18 January 2017, 9 March 2020 and 18 January 2021.
(2) The exemption under sub‑paragraph (1) is subject to the terms and conditions specified in the letter of approval dated 16 August 2021 and sent to Grace Ocean Private Limited.