2.—(1) Subject to sub‑paragraph (2), there shall be exempt from tax any payment in the nature of income referred to in section 12(6) of the Act made by Hitachi International Treasury Ltd on commercial paper notes issued under the US $800 million Commercial Paper Notes Programme during the period from 1st September 2003 to 31st August 2008 to any person who is not resident in Singapore and —| (a) | who carries on any operation in Singapore through a permanent establishment in Singapore where the funds used by that person to acquire the commercial paper notes under that programme are not obtained from that operation; or | | (b) | who does not have any permanent establishment in Singapore. |
| (2) The exemption in paragraph (1) is subject to the terms and conditions specified in the letter of approval dated 21st August 2003 and subsequent correspondences, if any, addressed to the company. |
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