NOTES TO THE FINANCIAL STATEMENTS
(CONT’D)
31 DECEMBER 2015
10.
INCOME TAX (CONT’D)
10C.
Deferred tax balance in the statements of financial position (cont’d):
Dividends from Indonesia Subsidiaries
Dividends received by the Singapore subsidiaries of the Trust from their respective Indonesia subsidiaries are
exempt from Singapore income tax under section 13(8) of the Income Tax Act provided the following conditions
are met:
(a)
In the year the dividends are received in Singapore, the headline corporate tax rate in the foreign
country from which the dividends are received is at least 15%;
(b)
The dividends have been subject to tax in the foreign country from which they are received; and
(c)
The Singapore Comptroller of Income Tax is satisfied that the tax exemption would be beneficial to the
Singapore subsidiaries.
Dividends from Singapore Subsidiaries
Dividends received by the Trust from the Singapore subsidiaries are exempt from Singapore income tax provided
that the Singapore subsidiaries are tax residents of Singapore for income tax purposes.
Interest Income from Indonesia Subsidiaries
Interest received by the Singapore subsidiaries of the Trust on loans made to the Indonesia subsidiaries is exempt
from Singapore income tax under section 13(12) of the Income Tax Act on the condition that the full amount of
remitted interest, less attributable expenses, is distributed by the Singapore subsidiaries to the Trust for onward
distribution to its Unitholders.
Redemption of Redeemable Preference Shares in Singapore Subsidiaries
Proceeds received by the Trust from the redemption of its redeemable preference shares in the Singapore
subsidiaries at the original cost of the redeemable preference shares are regarded as capital receipts and hence
not subject to Singapore income tax.
Receipt from Indonesia Subsidiaries for Repayment of Shareholder Loans
Proceeds received by the Singapore subsidiaries for the repayment of the principal amount of the shareholder
loans from their Indonesia subsidiaries are capital receipts and hence not subject to Singapore income tax.
ANNUAL REPORT 2015
99
