Singapore legislation
Regulation 2
of Income Tax (Azure Sky Investments 10 Pte Ltd, etc. — Section 13(4) Exemption) Notification 2020
Regulation 2
Exemption
Subregulation 1
The interest and legal fee 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 outstanding 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 mentioned in the fourth column of the table;
under the respective agreements mentioned in the fifth column of the table; and
that are due and payable during the respective periods mentioned in the sixth column of the table,are exempt from tax:First columnSecond columnThird columnFourth columnFifth columnSixth columnBorrowerLenderOutstanding loan amount US$AircraftAgreementPeriod (both dates inclusive)Azure Sky Investments 22 Pte LtdGE Japan Corporation13,500,000“MSN1046”Secured aircraft loan agreement dated 13 August 201415 August 2014 to 9 August 2018Azure Sky Investments 24 Pte LtdGE Japan Corporation35,000,000“MSN39820”Secured aircraft loan agreement dated 8 August 201412 August 2014 to 12 December 201735,000,000“MSN39829”16 December 2014 to 12 December 2017
Subregulation 2
The interest, legal fee and exposure fee payable —
by the borrowers mentioned in the first column of the following table;
to the respective lenders mentioned in the second column of the table;
in respect of the respective outstanding loan amounts mentioned in the third column of the table that are or are to be used for the purposes of financing the acquisition of the respective aircraft mentioned in the fourth column of the table; (d)under the respective agreement or promissory notes mentioned in the fifth column of the table; and
that are due and payable during the respective periods mentioned in the sixth column of the table,are exempt from tax:First columnSecond columnThird columnFourth columnFifth columnSixth columnBorrowerLenderOutstanding loan amount US$AircraftAgreement or Promissory notePeriod (both dates inclusive)Azure Sky Investments 10 Pte LtdApple Bank40,800,000“MSN38687”Secured aircraft loan agreement dated 8 March 201313 March 2013 to 12 December 201739,800,000“MSN38729”19 March 2013 to 12 December 2017Azure Sky Investments 14 Pte LtdApple Bank40,700,000“MSN38690”Secured promissory notes dated 3 June 201317 June 2013 to 12 September 201740,700,000“MSN38732”7 June 2013 to 12 September 201740,300,000“MSN38736”13 September 2013 to 16 September 201740,400,000“MSN38737”20 September 2013 to 16 September 2017
Subregulation 3
The interest, legal fee, arrangement fee, commitment fee and security trustee fee 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 outstanding 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 mentioned in the fourth column of the table;
under the respective agreements mentioned in the fifth column of the table; and
that are due and payable during the respective periods mentioned in the sixth column of the table,are exempt from tax:First columnSecond columnThird columnFourth columnFifth columnSixth columnBorrowerLenderOutstanding loan amount US$AircraftAgreementPeriod (both dates inclusive)Azure Sky Investments 21 Pte LtdGE Japan Corporation13,700,000“MSN1161”Secured aircraft loan agreement dated 18 July 201418 July 2014 to 18 October 201713,700,000“MSN1168”14 August 2014 to 18 October 201713,700,000“MSN1176”11 September 2014 to 11 September 201713,700,000“MSN1179”22 September 2014 to 11 September 201713,700,000“MSN1186”23 October 2014 to 23 October 201713,700,000“MSN1188”31 October 2014 to 23 October 201713,700,000“MSN1193”Secured aircraft loan agreement dated 22 December 201423 December 2014 to 25 September 201713,700,000“MSN1220”23 December 2014 to 25 September 2017Azure Sky Investments 25 Pte LtdSociete Generale, London Branch18,000,000“MSN1332”Secured aircraft loan agreement dated 27 June 201628 June 2016 to 28 June 201818,000,000“MSN1336”Secured aircraft loan agreement dated 29 June 201630 June 2016 to 28 June 201818,000,000“MSN1349”15 September 2016 to 15 June 201818,000,000“MSN1356” 4 October 2016 to 4 April 2018Azure Sky Investments 27 Pte LtdGE Japan Corporation14,400,000“MSN1263”Secured aircraft loan agreement dated 13 August 20156 October 2015 to 6 July 201814,400,000“MSN1271”18 August 2015 to 18 August 201814,400,000“MSN1275”1 October 2015 to 8 June 201814,400,000“MSN1282”1 October 2015 to 3 July 201814,400,000“MSN1290”5 November 2015 to 7 August 201814,400,000“MSN1291”8 December 2015 to 8 June 2018
Subregulation 4
The interest, legal fee, exposure fee, arrangement fee, commitment fee and security trustee fee 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 outstanding 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 mentioned in the fourth column of the table;
under the respective agreements or promissory notes mentioned in the fifth column of the table; and
that are due and payable during the respective periods mentioned in the sixth column of the table,are exempt from tax:First columnSecond columnThird columnFourth columnFifth columnSixth columnBorrowerLenderOutstanding loan amount US$AircraftAgreement or Promissory notePeriod (both dates inclusive)Azure Sky Investments 16 Pte LtdApple Bank37,500,000“MSN38739”Secured promissory notes dated 28 October 201329 October 2013 to 29 July 201837,800,000“MSN38748”14 March 2014 to 14 September 201737,900,000“MSN39823”8 September 2014 to 15 September 201738,900,000“MSN39824”22 September 2014 to 15 September 2017Azure Sky Investments 18 Pte LtdDevelopment Bank of Japan16,100,000“MSN1081”Secured aircraft loan agreement dated 19 March 201419 March 2014 to 5 September 201716,400,000“MSN1089”Secured aircraft loan agreement dated 18 March 201418 March 2014 to 5 September 201716,400,000“MSN1095”Secured aircraft loan agreement dated 13 March 201413 March 2014 to 5 September 201716,900,000“MSN1123”13 March 2014 to 5 September 201716,900,000“MSN1130”Secured aircraft loan agreement dated 14 March 201414 March 2014 to 5 September 2017Azure Sky Investments 18 Pte LtdAeronautic Investments 18 LLC13,900,000“MSN1081”Refinancing promissory note dated 17 December 201517 December 2015 to 5 September 201714,200,000“MSN1089”17 December 2015 to 5 September 201714,200,000“MSN1095”17 December 2015 to 5 September 201714,900,000“MSN1123”17 December 2015 to 5 September 201714,900,000“MSN1130”17 December 2015 to 5 September 2017Azure Sky Investments 26 Pte LtdApple Bank38,000,000“MSN38304”Guaranteed promissory note dated 18 November 20144 December 2014 to 5 June 2018
Subregulation 5
The exemptions in sub‑paragraphs (1), (2), (3) and (4) are subject to the conditions specified in the letter of approval dated 7 June 2019 issued by the Ministry of Finance and addressed to Transportation Partners Pte Ltd.