Regulation 3

where the total amount of all the specified loans or indebtedness mentioned in sub‑paragraph (1) exceeds US$10 billion — to any interest, commission, fee or other payment mentioned in that sub‑paragraph, that is payable on the first US$10 billion that is disbursed;

if each specified loan or indebtedness is $5 million or more;

if each specified loan or indebtedness is entered into between the lender and the borrower on an arm’s length basis;

subject to sub‑paragraph (3), where A is a related party of the borrower, if at the time the interest, commission, fee or other payment is payable to A, the highest rate of tax of a similar character to income tax (by whatever name called) that is levied —

under the law of the territory that A is a tax resident in; and

on any gains or profits from any trade or business carried on by A in that territory at that time,is more than 0%; and

if the interest rate for each specified loan or indebtedness is comparable to the market rate for other similar loans or indebtedness, if any.

any interest, commission, fee or other payment derived from any operation carried on by A through A’s permanent establishment in Singapore; or

any interest, commission, fee or other payment that is due and payable after the earliest of the following:

the date of maturity of the specified loan or indebtedness;

30 September 2026;

the last date on which Trafigura Pte Ltd is an approved global trading company under section 43I of the Act.