/akn/sg/act/sub_leg/1947/ITA-S748-2018
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Income Tax (Exemption of Interest and Other Payments on Economic and Technological Development Loans) (No. 5) Notification 2018 is Singapore Subsidiary Legislation, cited as Subsidiary Legislation ITA-S748-2018 1947, currently marked in force and first recorded in 1947.
Citation and commencement
This Notification is the Income Tax (Exemption of Interest and Other Payments on Economic and Technological Development Loans) (No. 5) Notification 2018 and is deemed to have come into operation on 26 July 2018.
Definitions
In this Notification —“Additional Notes” means the debt securities known as Additional Notes —
issued by Blue Ocean Resources Pte. Ltd. under the information memorandum to replace any Original Notes; and
that mature on 31 December 2021;“Guaranteed Senior Secured Notes” means the debt securities known as Guaranteed Senior Secured Notes —
issued by Blue Ocean Resources Pte. Ltd. under the information memorandum to replace any Original Notes; and
that mature on 31 December 2021;“information memorandum” means the information memorandum issued by PT Central Proteina Prima, Tbk., guarantor of the Guaranteed Senior Secured Notes and the Additional Notes, on 28 March 2018;“Original Notes” means the debt securities —
issued by Blue Ocean Resources Pte. Ltd. under an indenture dated 28 June 2007, that mature on 28 June 2012; and
subsequently reissued by Blue Ocean Resources Pte. Ltd. under a scheme of arrangement dated 17 June 2013, as debt securities that mature on 31 December 2020.
“Additional Notes” means the debt securities known as Additional Notes —
issued by Blue Ocean Resources Pte. Ltd. under the information memorandum to replace any Original Notes; and
that mature on 31 December 2021;
“Guaranteed Senior Secured Notes” means the debt securities known as Guaranteed Senior Secured Notes —
issued by Blue Ocean Resources Pte. Ltd. under the information memorandum to replace any Original Notes; and
that mature on 31 December 2021;
“information memorandum” means the information memorandum issued by PT Central Proteina Prima, Tbk., guarantor of the Guaranteed Senior Secured Notes and the Additional Notes, on 28 March 2018;
“Original Notes” means the debt securities —
issued by Blue Ocean Resources Pte. Ltd. under an indenture dated 28 June 2007, that mature on 28 June 2012; and
subsequently reissued by Blue Ocean Resources Pte. Ltd. under a scheme of arrangement dated 17 June 2013, as debt securities that mature on 31 December 2020.
Exemption
The interest payable during the period starting on 26 July 2018 and ending on 31 December 2021, by Blue Ocean Resources Pte. Ltd. to any person who is not resident in Singapore, in respect of the Guaranteed Senior Secured Notes and the Additional Notes, is exempt from tax.
The exemption under sub-paragraph (1) does not apply to any Guaranteed Senior Secured Notes or Additional Notes, if the Original Notes which the Guaranteed Senior Secured Notes or the Additional Notes replaced, are obtained by the person to whom the interest is payable using funds obtained through the operation of any permanent establishment of the person in Singapore.
The exemption under sub-paragraph (1) is subject to the terms and conditions specified in the letter of approval dated 21 December 2017 and addressed to RPC Premier Law Pte Ltd, legal representative of Blue Ocean Resources Pte. Ltd.