3.—(1) The front‑end fees and interest payable by Grace Ocean Private Limited to The Hiroshima Bank, Ltd in respect of an outstanding loan amount of JPY 365,898,592 as at 18 January 2021 under a loan agreement dated 11 April 2011 (as amended by supplemental agreements dated 25 August 2015, 7 December 2017 and 18 January 2021), being a loan made for the purpose of financing the acquisition of the vessel “CS Service”, are exempt from tax.
(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.