Clause 4

any interest, commission, fees or any other payments in connection with any loan or indebtedness or with any arrangement, management, guarantee, or service relating to any loan or indebtedness which are —

borne directly or indirectly by a person resident in Singapore or a permanent establishment in Singapore except in respect of any business carried on outside Singapore through a permanent establishment outside Singapore or any immovable property situated outside Singapore; or

deductible against any income accruing in or derived from Singapore; or

any income derived from loans where the funds provided by such loans are brought into or used in Singapore.(7) There shall be deemed to be derived from Singapore —

royalty or other payments in one lump sum or otherwise for the use of or the right to use any movable property;

any payment for the use of or the right to use scientific, technical, industrial or commercial knowledge or information or for the rendering of assistance or service in connection with the application or use of such knowledge or information;

any payment for the management or assistance in the management of any trade, business or profession; or

rent or other payments under any agreement or arrangement for the use of any movable property,which are borne directly or indirectly by a person resident in Singapore or a permanent establishment in Singapore (except in respect of any business carried on outside Singapore through a permanent establishment outside Singapore) or which are deductible against any income accruing in or derived from Singapore.”.