Singapore legislation
Regulation 2
of Income Tax (Cromwell SG SPV 5 Pte Ltd — Section 13(12) Exemption) Order 2021
Regulation 2
Exemption
Subregulation 1
Income comprising dividends and interest described in sub‑paragraph (2), that is received in Singapore by Cromwell SG SPV 5 Pte. Ltd. on or after 30 November 2017 from Cromwell EREIT Lux 5 S.a r.l. (a company incorporated in Luxembourg), is exempt from tax.
Subregulation 2
Sub-paragraph (1) applies to distribution income received by Cromwell EREIT Lux 5 S.a r.l. from Cromwell Europa 1 and Cromwell Europa 2 which are real estate investment funds constituted in Italy, out of the rental and property‑related income (including capital gains) of Cromwell Europa 1 and Cromwell Europa 2 from any of the properties specified in the Schedule.
Subregulation 3
The exemption under sub‑paragraph (1) is subject to the conditions specified in the letter of approval dated 8 May 2020 addressed to EY Corporate Advisors Pte. Ltd.