2.—(1) Income comprising dividends described in sub‑paragraph (2), that are received by Cofco Agri Holdings Pte Ltd (a company incorporated in Singapore) on or after 20 May 2016 from Noble Agri Resources Limited (a company incorporated in Bermuda), is exempt from tax.| (2) Sub‑paragraph (1) applies to dividends derived from dividends received by Noble Agri Resources Limited from the companies set out in the Schedule, which are in turn derived by those companies from carrying out their respective business activities. |
| (3) The exemption in sub‑paragraph (1) is subject to the terms and conditions specified in the letter of approval dated 20 May 2016 addressed to the tax agent of Cofco Agri Holdings Pte Ltd. |
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