2.—(1) Income comprising dividends described in sub‑paragraph (2), that is received in Singapore by AT Holdings Pte. Ltd. (a company incorporated in Singapore) from AT Holdings Europe Co‑operative U.A. (a company incorporated in the Netherlands), is exempt from tax.(2) Sub-paragraph (1) applies to dividends that are derived from dividends received by AT Holdings Europe Co‑operative U.A., that are in turn derived from profits of the following entities: | (a) | Retail Asset Investment 2 B.V.; | | (b) | Bajes Kwartier B.V.; | | (c) | Bajes Kwartier Ontwikkeling C.V.; | | (d) | Experion Construction Europe B.V.; | | (e) | Experion Participaties B.V.; | | (f) | Sterpassage Rijswijk Beheer B.V.; | | (g) | Sterpassage Rijswijk C.V. |
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| (3) The exemption under sub‑paragraph (1) is subject to the conditions specified in the letter of approval dated 24 September 2020 addressed to AT Holdings Pte. Ltd. |
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