2.—(1) The front‑end fees and interest payable by Grace Ocean Private Limited to The Hiroshima Bank, Ltd in respect of the following amounts under a loan agreement dated 25 March 2011 as amended under the respective supplemental agreements, being a loan made for the purpose of financing the acquisition of the vessel “CS Best”, are exempt from tax:| (a) | USD 4,079,530.82 outstanding as at 9 March 2020 under the loan agreement as amended by supplemental agreements dated 25 August 2015, 18 January 2017 and 9 March 2020; | | (b) | JPY 248,140,437 outstanding as at 18 January 2021 under the loan agreement as amended by supplemental agreements dated 25 August 2015, 18 January 2017, 9 March 2020 and 18 January 2021. |
| (2) The exemption under sub‑paragraph (1) is subject to the terms and conditions specified in the letter of approval dated 16 August 2021 and sent to Grace Ocean Private Limited. |
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