Singapore legislation
Regulation 2
of Income Tax (Cromwell SG SPV 5 Pte. Ltd. — Section 13(12) Exemption) Order 2022
Regulation 2
Exemption
Subregulation 1
Dividend income described in sub‑paragraph (2), that is received in Singapore by Cromwell SG SPV 5 Pte. Ltd. on or after 17 February 2022 from Cromwell EREIT Lux 5 S.a r.l. (a company incorporated in Luxembourg), is exempt from tax.
Subregulation 2
Sub‑paragraph (1) applies to dividend income paid out of distribution income received by Cromwell EREIT Lux 5 S.a r.l. from Cromwell Europa 1 and Cromwell Europa 2 (being real estate investment funds constituted in Italy), which is in turn paid out of —
any rental and property‑related income (including capital gains) of Cromwell Europa 1 and Cromwell Europa 2 from the specified property; and
any interest income derived from any deposit with a financial institution of such rental and property‑related income.
Subregulation 3
The exemption in sub‑paragraph (1) is subject to the conditions specified in the letter of approval dated 17 February 2022 addressed to EY Corporate Advisors Pte. Ltd.
Subregulation 4
In sub‑paragraph (2), “specified property” means the property named “Centro Logistico Orlando Marconi” located at Via del Lavoro, Monteprandone, Italy.