Singapore legislation

Regulation 2

of Income Tax (Trafigura Holdings Pte Ltd — Section 13(12) Exemption) Order 2023

Regulation 2

Exemptions

Subregulation 1

Dividend income received in Singapore by Trafigura Holdings Pte Ltd (a company incorporated in Singapore) after 1 December 2019 from Cortes Investments S.á.r.l. (a company incorporated in Luxembourg), which is in turn derived from the profits of any of the following companies, is exempt from tax:

(a)

Galena Asset Management (Asia) Pte Ltd (a company incorporated in Singapore);

(b)

Puma Energy Holdings Pte Ltd (a company incorporated in Singapore);

(c)

Trafigura Pte Ltd (a company incorporated in Singapore);

(d)

Trafigura Overseas Project Pte Ltd (a company incorporated in Singapore).

Subregulation 2

Dividend income received in Singapore by Trafigura Holdings Pte Ltd after 1 December 2019 from Trafigura Holdings Limited (a company incorporated in Malta), which is in turn derived from the profits of Pan‑African Soleil Holdings Pte Ltd (a company incorporated in Singapore), is exempt from tax.

Subregulation 3

The exemptions in sub-paragraphs (1) and (2) are subject to the conditions specified in the letters from the Ministry of Finance dated 29 August 2023 and 3 October 2023, and addressed to KPMG Services Pte. Ltd.