Singapore legislation
Regulation 2
of Income Tax (Dreymoor Fertilizers Overseas Pte. Ltd. — Section 13(4) Exemption) Notification 2022
Regulation 2
Exemption
Subregulation 1
Subject to sub‑paragraphs (2) and (3), the interest payable by Dreymoor Fertilizers Overseas Pte. Ltd. from 1 June 2019 to 31 December 2022 (both dates inclusive) to the financial institutions not resident in Singapore mentioned in the first column of the following table in connection with the respective amounts of facility or loan quantum of foreign trade financing facility mentioned in the second column of the table, is exempt from tax:First columnSecond columnName of financial institutionnot resident in SingaporeAmount of facility or loan quantum of foreign trade financing facilityCredit Europe Bank N.V.US$50 millionBIC-Bred (Suisse) S.A.US$20 millionSberbank (Switzerland) A.G.US$50 millionGarantiBank International N.V.US$20 million
Subregulation 2
The exemption in sub-paragraph (1) does not apply to —
any interest payment derived from any operation carried on by the financial institution through the financial institution’s permanent establishment in Singapore; and (b)any interest payment due and payable after the date on which Dreymoor Fertilizers Overseas Pte. Ltd. ceases to be an approved global trading company under section 43I of the Act.
Subregulation 3
The exemption in sub‑paragraph (1) is subject to the conditions specified in the letter from the Ministry of Finance dated 17 January 2022 and addressed to Ernst & Young Solutions LLP.