Singapore legislation
Regulation 2
of Income Tax (Trafigura Group Pte Ltd — Section 13(4) Exemption) (No. 2) Notification 2020
Regulation 2
Exemption
Subregulation 1
Subject to sub‑paragraph (3), the interest, commission, fee and other payments payable by Trafigura Group Pte Ltd to any person who is not resident in Singapore —
in connection with the bonds denominated in Chinese Renminbi and issued in the People’s Republic of China by Trafigura Group Pte Ltd that are specified in sub‑paragraph (2); or
in connection with any arrangement, management, guarantee, or services relating to such bonds,that are due and payable up to (and including) the date of maturity of the bonds, are exempt from tax.
Subregulation 2
The bonds in sub‑paragraph (1) are those —
issued on the dates mentioned in the first column of the following table;
maturing on the respective dates mentioned in the second column of the table; and
having the respective issue sizes mentioned in the third column of the table:First columnSecond columnThird columnDate of issueDate of maturityIssue size (RMB)27 April 201827 April 2021500 million24 May 201824 May 2021500 million28 Sep 201828 Sep 2021700 million20 May 201920 May 2022540 million
Subregulation 3
The exemption under sub‑paragraph (1) does not apply to —
any interest, commission, fee or other payments derived from any operation carried on by the person through the person’s permanent establishment in Singapore; or
any interest, commission, fee or other payments that are due and payable after the date on which Trafigura Pte Ltd (a subsidiary of Trafigura Group Pte Ltd) ceases to be an approved global trading company under section 43P of the Act.
Subregulation 4
The exemption in sub‑paragraph (1) is subject to the conditions specified in the letter of approval dated 4 January 2017 issued by the International Enterprise Singapore Board addressed to Trafigura Group Pte Ltd.