Regulation 4

The income received in Singapore by Steppe Capital Pte Ltd, comprising distributions from the Co‑operative or dividends from any Holding Company, is exempt from tax if the income is —

The exemption in sub‑paragraph (1) does not apply to any distribution or dividend declared out of the income of the Co‑operative or Holding Company (as the case may be) that is directly or indirectly derived from an ultimate entity.

For the purposes of sub‑paragraph (2), the income of an entity (A) is indirectly derived from another entity (B) if the income of A is derived from another entity whose income is in turn directly or indirectly derived (including by one or more applications of this sub‑paragraph) from B.

The exemption in sub‑paragraph (1) is subject to the terms and conditions specified in paragraphs 4 and 5 of the letter of approval dated 25 February 2013 addressed to the tax agent of Steppe Capital Pte Ltd, which are incorporated by reference in paragraph 6 of the letter of approval dated 14 May 2014 addressed to Steppe Capital Pte Ltd.

In this paragraph, “ultimate entity” means an entity that is set out in the Second Schedule.