Regulation 1
Citation
This Notification may be cited as the Income Tax (Exemption of Interest and Other Payments for Economic and Technological Development) Notification.
/akn/sg/act/sub_leg/1947/ITA-N13
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Income Tax (Exemption of Interest and Other Payments for Economic and Technological Development) Notification is Singapore Subsidiary Legislation, cited as Subsidiary Legislation ITA-N13 1947, currently marked in force and first recorded in 1947.
Citation
This Notification may be cited as the Income Tax (Exemption of Interest and Other Payments for Economic and Technological Development) Notification.
Exemption
This paragraph applies to any payment —
made by a Singapore swap counterparty to an issuer of Singapore dollar debt securities who is not resident in Singapore;
that is not derived through any operation carried on by the issuer through the issuer’s permanent establishment in Singapore; and
that is liable to be made —
under a contract for a cross currency swap transaction, where the contract takes effect on a date that falls within the period from 3 March 1999 to 31 December 2026 (both dates inclusive) (called in this sub‑paragraph the relevant period); (ii)under a contract for a cross currency swap transaction that is extended or renewed, where —
the extension or renewal of the contract takes effect on a date that falls within the relevant period; and
the payment is made on or after the date on which such extension or renewal takes effect; or
under a contract for a cross currency swap transaction that is varied, where —
the variation of the contract takes effect on a date that falls within the period from 4 November 2022 to 31 December 2026 (both dates inclusive); and (B)the payment is made on or after the date on which such variation takes effect.
However, this paragraph does not apply to a payment liable to be made —
under a contract for a cross currency swap transaction mentioned in sub-paragraph (1)(c)(i), (ii) and (iii), that is varied with effect from a date on or after 1 January 2027; and (b)on or after the date on which such variation takes effect.
Subject to paragraph 3, any payment to which this paragraph applies is exempt from tax.
Terms and conditions of exemption
The exemption under paragraph 2 shall apply only if the following terms and conditions are satisfied:
the issuer has been approved by the Monetary Authority of Singapore (the Authority) to issue Singapore dollar debt securities under the Authority’s guidelines on internationalisation of the Singapore dollar (the Internationalisation Guidelines);
the Singapore swap counterparty is a licensed bank or merchant bank or any other institution specifically approved by the Authority to enter into the cross currency swap transaction; and
the cross currency swap transaction is entered into pursuant to the requirements of the Internationalisation Guidelines to convert the proceeds from the Singapore-dollar denominated debt securities into foreign currency.