Singapore legislation

Regulation 2

of Income Tax (Trafigura Group Pte. Ltd., etc. — Section 13(4) Exemption) Notification 2025

Regulation 2

Definitions

In this Notification —“relevant person” means Trafigura Group Pte. Ltd., Trafigura Pte Ltd or a satellite entity;“satellite entity” means any of the following:

(a)

Trafigura Maritime Logistics Pte. Ltd.; (b)Trafigura Commodities Funding Pte. Ltd.;

(c)

TFG Marine Pte. Ltd.; (d)Trafigura Asia Trading Pte. Ltd.; (e)Trafigura Global Commodities Funding Pte. Ltd.; (f)CB Enterprises Pte. Ltd.; (g)Pan‑African Soleil Holdings Pte. Ltd.; (h)Puma Energy Irrawaddy Holding Pte. Ltd.; (i)Puma Energy Supply & Trading Pte. Ltd.;“specified loan or indebtedness” means any loan or indebtedness that —

(a)

is incurred by a relevant person to a non‑resident person;

(b)

is incurred for the purpose of a trading activity or trading‑related activity;

(c)

arises under or in connection with any of the following: (i)a corporate security, including a medium term note or a variable funding note;

(ii)

a private placement of securities;

(iii)

a perpetual security;

(iv)

a term loan;

(v)

a revolving credit facility;

(vi)

an asset securitisation arrangement;

(vii)

a repurchase agreement;

(viii)

a borrowing base facility;

(ix)

a bilateral line facility; and

(d)

is notified to the Inland Revenue Authority of Singapore and the Enterprise Singapore Board at any time on or after 1 January 2018 but on or before 30 September 2021;“trading activity” means any activity carried on in the course of a business of international trading of commodities or commodities derivatives, including —

(a)

the financing of inventories;

(b)

the financing of trade receivables; and

(c)

the financing of working capital used specifically for trading purposes, including —

(i)

overheads;

(ii)

storage;

(iii)

margin calls on derivative positions; and

(iv)

any other activity undertaken by any relevant person,but excluding working capital used for the cost of utilities, the cost of Internet services or any other purpose that does not specifically relate to trading purposes;“trading‑related activity” means any investment in or construction of any asset, carried on by a relevant person, that supports a trading activity, including —

(a)

any investment in or construction of infrastructure that supports trading activities such as vessels, oil terminals and warehouses; and

(b)

any investment in or construction of infrastructure that supports commodity customers and commodity suppliers of trading activities, such as service stations and mines.

Definition

“relevant person” means Trafigura Group Pte. Ltd., Trafigura Pte Ltd or a satellite entity;

Definition

“satellite entity” means any of the following:

(a)

Trafigura Maritime Logistics Pte. Ltd.; (b)Trafigura Commodities Funding Pte. Ltd.;

(c)

Definition

“specified loan or indebtedness” means any loan or indebtedness that —

(a)

is incurred by a relevant person to a non‑resident person;

(b)

is incurred for the purpose of a trading activity or trading‑related activity;

(c)

arises under or in connection with any of the following: (i)a corporate security, including a medium term note or a variable funding note;

(ii)

a private placement of securities;

(iii)

a perpetual security;

(iv)

a term loan;

(v)

a revolving credit facility;

(vi)

an asset securitisation arrangement;

(vii)

a repurchase agreement;

(viii)

a borrowing base facility;

(ix)

a bilateral line facility; and

(d)

is notified to the Inland Revenue Authority of Singapore and the Enterprise Singapore Board at any time on or after 1 January 2018 but on or before 30 September 2021;

Definition

“trading activity” means any activity carried on in the course of a business of international trading of commodities or commodities derivatives, including —

(a)

the financing of inventories;

(b)

the financing of trade receivables; and

(c)

the financing of working capital used specifically for trading purposes, including —

(i)

overheads;

(ii)

storage;

(iii)

margin calls on derivative positions; and

(iv)

Definition

“trading‑related activity” means any investment in or construction of any asset, carried on by a relevant person, that supports a trading activity, including —

(a)

any investment in or construction of infrastructure that supports trading activities such as vessels, oil terminals and warehouses; and

(b)

any investment in or construction of infrastructure that supports commodity customers and commodity suppliers of trading activities, such as service stations and mines.

Read in full context — Income Tax (Trafigura Group Pte. Ltd., etc. — Section 13(4) Exemption) Notification 2025 →