Singapore legislation
Regulation 2
of Income Tax (Hevilift Group Pte Ltd, etc. — Section 13(4) Exemption) Notification 2020
Regulation 2
Exemption
Subregulation 1
The interest payable —
by the borrowers mentioned in the first column of the following table;
to the respective lenders mentioned in the second column of the table;
in respect of the respective loan amounts mentioned in the third column of the table that are or are to be used for the purposes of financing the acquisition of the respective aircraft or aircraft engines mentioned in the fourth column of the table;
under the respective agreements mentioned in the fifth column of the table; and
that is due and payable during the respective periods mentioned in the sixth column of the table,is exempt from tax:First columnSecond columnThird columnFourth columnFifth columnSixth columnBorrowerLenderLoan amount US$Aircraft or aircraft enginesAgreementPeriod (both dates inclusive)Hevilift Group Pte LtdPetroleum Resources Kutubu Limited1,700,000Aircraft “MSN53447”, “MSN53054”, “MSN53294”, “MSN53141”, “MSN30584”, “MSN760408”, “MSN194”, “MSN96”, “MSN875”, “MSN280”, “MSN592”, “MSN673”, “MSN703” and “MSN120030”Revolving loan agreement dated 28 March 201428 March 2014 to 31 December 20143,300,000Revolving loan agreement dated 1 May 201420 May 2014 to 31 December 2014Hevilift Leasing Pte LtdBank of South Pacific Ltd20,000,000Refinancing loan agreement dated 20 September 201225 September 2012 to 31 December 20145,000,000Greystoke Leasing Inc2,700,000Aircraft “MSN634”Aircraft engines “PCE41804” and “PCE41852”Finance lease treated as a sale dated 12 August 20111 January 2012 to 31 December 2014
Subregulation 2
The exemption under sub‑paragraph (1) is subject to the conditions specified in the letter of approval dated 7 June 2019 issued by the Ministry of Finance and addressed to PricewaterhouseCoopers Singapore Pte Ltd.