Singapore legislation

Regulation 3

of Income Tax (Exemption of Foreign Income) Order 2016

Regulation 3

Exemption

Subregulation 1

Fraser & Neave, Limited is granted exemption from tax on the capital gains dividends and income dividends received in Singapore from its subsidiary, Fraser & Neave Holdings Bhd, a company incorporated in Malaysia.

Subregulation 2

The exemption in sub‑paragraph (1) is subject to the terms and conditions specified in the letters of approval dated 15 August 2014 and 26 February 2015 addressed to Allen & Gledhill LLP, the tax agent of Fraser & Neave, Limited.

Subregulation 3

In this paragraph —

Definition

“capital gains dividends” means dividends which are declared out of capital gains of Fraser & Neave Holdings Bhd arising from any one or more of the following:

(a)

disposal of shares in Malaya Glass Products Sdn Bhd and Brampton Holdings Sdn Bhd;

(b)

writing‑back of excess provision for costs in connection with the disposal of shares in Malaya Glass Products Sdn Bhd;

(c)

the share capital reduction exercise undertaken by Fraser & Neave (Malaya) Sdn Bhd on 25 May 2010;

(d)

unrealised foreign exchange gains;

Definition

“income dividends” means dividends which are —

(a)

declared out of the income of Fraser & Neave Holdings Bhd, being income received (directly or indirectly) from a company in the first column of the Schedule and paid out of the company’s capital gains or income specified in the second column of the Schedule corresponding to the company; and

(b)

received by Fraser & Neave, Limited in Singapore —

(i)

on a date in the third column of the Schedule corresponding to the company; and

(ii)

in a scenario in the fourth column of the Schedule corresponding to the company (if applicable).

Read in full context — Income Tax (Exemption of Foreign Income) Order 2016 →