TAXATION SINGAPORE TAXATION

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1 TAXATION SINGAPORE TAXATION The comments below are of a general nature and, a summary of certain Singapore tax consequences of the acquisition, ownership and disposal of our Shares. It is not intended to be and does not constitute legal or tax advice. This summary is based upon tax laws, regulations, rulings and decisions, or in the interpretation thereof, now in effect, all of which are subject to changes. Such changes may be retrospective. While the comments are considered to be a correct interpretation of existing laws in force as of the Latest Practicable Date, no assurance can be given that courts or fiscal authorities responsible for the administration of such laws will agree with this interpretation or that changes in such laws will not occur. The discussion below is not intended to constitute a complete analysis of all of the Singapore tax consequences relating to the acquisition, ownership and disposal of our Shares by any person. Each prospective investor in our Shares should therefore consult its own tax advisers concerning the tax consequences of an investment in our Shares. The following discussion has been prepared on the basis that our Company is tax resident in Singapore. Income tax Corporate income tax Singapore tax resident corporate taxpayers are subject to Singapore income tax on income accruing in or derived from Singapore and on income derived from sources outside Singapore (i.e. foreign-sourced income) that is received or deemed to have been received in Singapore by the operation of law, subject to certain exceptions. Foreign-sourced income in the form of dividends, branch profits and service income received or deemed to have been received in Singapore by Singapore tax resident corporate taxpayers is exempt from Singapore income tax if the following conditions are met: k k k the income is subject to tax of a similar character to income tax under the law of the jurisdiction from which such income is received; at the time the income is received in Singapore, the highest rate of tax of a similar character to income tax in the jurisdiction from which the income is received is at least 15.0%; and the Comptroller of Income Tax is satisfied that the tax exemption would be beneficial to the recipient of the foreign-sourced income. A special concession has been granted to exempt from Singapore income tax all foreign-sourced income earned on or before January 21, 2009 and received in Singapore during the one-year period from January 22, 2009 to January 21, Non-Singapore tax resident corporate taxpayers are subject to Singapore income tax on income accruing in or derived from Singapore, and on foreign-sourced income that is received or deemed to have been received in Singapore, subject to certain exceptions. Individual income tax An individual taxpayer (both resident and non-resident) is subject to Singapore income tax on income accruing in or derived from Singapore, subject to certain exceptions. Foreign-sourced income received or deemed to have been received by a Singapore tax resident individual is exempt from income tax in Singapore, except where such income is received through a partnership in Singapore. Foreign-sourced income received or deemed to have been received by a non-singapore tax resident individual is exempt from income tax in Singapore. Certain Singapore-sourced investment income received by individuals is also exempt from income tax in Singapore. Tax residency A company is regarded as tax resident in Singapore if the control and management of its business is exercised in Singapore. Normally, control and management of the company is vested in its board of directors and the place of residence of the company is where its directors meet. 180

2 An individual is regarded as tax resident in Singapore if the individual is physically present in Singapore or exercises an employment in Singapore (other than as a director of a company) for 183 days or more in the calendar year preceding the year of assessment, or if the individual ordinarily resides in Singapore. Rates of tax The corporate tax rate in Singapore is 18.0% with effect from the year of assessment 2008 (i.e. in respect of income earned during the financial year or other basis period ending in 2007), with certain exemptions granted on the first S$300,000 of chargeable income. It has been proposed in the 2009 Singapore Budget that the corporate tax rate in Singapore will be reduced to 17.0% with effect from the year of assessment 2010 (i.e. in respect of income earned during the financial year or other basis period ending in 2009). Singapore tax-resident individuals are subject to tax on their taxable income based on progressive tax rates, currently ranging from 0.0% to 20.0%. Non-Singapore tax resident individuals are generally taxed at the tax rate of 20.0% on their taxable income. Dividend distributions Singapore adopts a one-tier corporate tax system. Under the one-tier corporate tax system, the tax paid by Singapore tax resident companies is a final tax. Any dividends paid by Singapore tax resident companies are exempt from Singapore income tax in the hands of their shareholders. As our Company is a Singapore tax resident, the dividends payable by our Company will be one-tier tax-exempt dividends and will be exempt from Singapore income tax in the hands of our shareholders, regardless of their legal form or tax residence status. There will be no tax credits attached to these dividends. There is no withholding tax on payment of dividends to non-resident shareholders. Gains on disposal of our Shares Singapore currently does not impose tax on capital gains. However, there are no specific laws or regulations which deal with the characterization of whether a gain is income or capital in nature. Gains arising from the disposal of our Shares may be construed to be income in nature and subject to Singapore income tax, especially if they arise from or are otherwise connected with the activities of a trade or business in Singapore. Such gains may also be considered income in nature, even if they do not arise from an activity in the ordinary course of trade or business or an ordinary incident of some other business activity, if our Shares were purchased with the intention or purpose of making a profit by sale and not with the intention to be held for long-term investment purposes. For shareholders who are subject to the income tax treatment provided for under Section 34A of the Income Tax Act (Chapter 134 of Singapore) in relation to the adoption of Financial Reporting Standard 39 - Financial Instruments: Recognition and Measurement ( FRS 39 ) for accounting purposes, they may be required to recognize gains or losses (not being gains or losses in the nature of capital) even though no sale or disposal of our Shares is made. Shareholders who may be subject to such provisions should consult their own accounting and tax advisers regarding the Singapore income tax consequences of their acquisition, ownership and disposal of our Shares. Stamp duty There is no stamp duty payable on the subscription and issuance of our Shares. Stamp duty is payable on an instrument of transfer of our Shares at the rate of S$2.00 for every S$1,000 or any part thereof, computed on the consideration for, or market value of our Shares, whichever is higher. Stamp duty is payable by the purchaser of our Shares, unless there is an agreement to the contrary. No stamp duty is payable if no instrument of transfer is executed (such as in the case of scripless shares, the transfer of which does not require an instrument of transfer to be executed) or if the instrument of transfer is executed outside Singapore. However, stamp duty may be payable if the instrument of transfer which is executed outside Singapore is subsequently received in Singapore. Stamp duty is also not applicable to electronic transfers of our Shares through the CDP. 181

3 Goods and services tax ( GST ) The sale of our Shares by a GST-registered investor belonging in Singapore for GST purposes through an SGX-ST member or to another person belonging in Singapore is an exempt supply not subject to GST. Any input GST incurred by the GST-registered investor in making such an exempt supply is generally not recoverable from the Comptroller of GST. Where our Shares are sold by a GST-registered investor in the course of or furtherance of a business carried on by such investor to a person belonging outside Singapore and that person is outside Singapore when the sale is executed, the sale should generally, subject to satisfaction of certain conditions, be considered a taxable supply subject to GST at zero-rate. Subject to the normal rules for input tax claims, any input GST incurred by the GSTregistered investor in making such a taxable supply in the course of or furtherance of a business carried on by such investor may generally be recoverable from the Comptroller of GST. Services consisting of arranging, broking, underwriting or advising on the issue, allotment or transfer of ownership of our Shares rendered by a GST-registered person to an investor belonging in Singapore for GST purposes in connection with the investor s purchase, sale or holding of our Shares will be subject to GST at the current standard rate of 7.0%. Similar services rendered to an investor belonging outside Singapore should generally, subject to satisfaction of certain conditions, be subject to GST at zero-rate, provided that the investor is outside Singapore when the services are performed and the services provided do not directly benefit any Singapore persons. Estate duty Singapore estate duty has been abolished with effect from February 15, UNITED STATES FEDERAL INCOME TAXATION TO ENSURE COMPLIANCE WITH INTERNAL REVENUE SERVICE (IRS) CIRCULAR 230, EACH TAXPAYER IS HEREBY NOTIFIED THAT: (A) ANY TAX DISCUSSION HEREIN IS NOT INTENDED OR WRITTEN TO BE USED, AND CANNOT BE USED BY THE TAXPAYER FOR THE PURPOSE OF AVOIDING US FEDERAL INCOME TAX PENALTIES THAT MAY BE IMPOSED ON THE TAXPAYER; (B) ANY SUCH TAX DISCUSSION WAS WRITTEN TO SUPPORT THE PROMOTION OR MARKETING OF THE TRANSACTIONS OR MATTERS ADDRESSED HEREIN; AND (C) THE TAXPAYER SHOULD SEEK ADVICE BASED ON THE TAXPAYER S PARTICULAR CIRCUMSTANCES FROM AN INDEPENDENT TAX ADVISER. The following is a summary of certain US federal income tax considerations relevant to US Holders (as defined below) acquiring, holding and disposing of Offering Shares. This summary is based on the US Internal Revenue Code of 1986 (the Code ), final, temporary and proposed US Treasury regulations, administrative and judicial interpretations, all of which are subject to change, possibly with retroactive effect. This summary does not discuss all aspects of US federal income taxation that may be relevant to investors in light of their particular circumstances, such as investors subject to special tax rules (including, without limitation: (i) financial institutions; (ii) insurance companies; (iii) dealers in stocks, securities, or currencies or notional principal contracts; (iv) regulated investment companies; (v) real estate investment trusts; (vi) tax-exempt organisations; (vii) partnerships, pass-through entities, or persons that hold Offering Shares through passthrough entities; (viii) holders that are not US Holders; (ix) holders that own (directly, indirectly or constructively) 10.0% or more of the voting stock of the Company; (x) investors that hold Offering Shares as part of a straddle, hedge, conversion, constructive sale or other integrated transaction for US federal income tax purposes; (xi) investors that have a functional currency other than the US dollar and (xii) US expatriates and former long-term residents of the United States), all of whom may be subject to tax rules that differ significantly from those summarized below. This summary does not address tax consequences applicable to holders of equity interests in a holder of the Offering Shares, US federal estate, gift or alternative minimum tax considerations, or non-us, state or local tax considerations. This summary only addresses investors that will acquire Offering Shares in the Offering, and it assumes that investors will hold their Offering Shares as capital assets (generally, property held for investment). For the purposes of this summary, a US Holder is a beneficial owner of Offering Shares that is for US federal income tax purposes (i) an individual who is a citizen or resident of the United States, (ii) a corporation created in, or organised under the laws of, the United States or any state thereof, including the District of Columbia, (iii) an 182

4 estate the income of which is includible in gross income for US federal income tax purposes regardless of its source or (iv) a trust that is subject to US tax on its worldwide income regardless of its source. Dividends Subject to the passive foreign investment company ( PFIC ) rules discussed below, a distribution made by us on the Offering Shares will be treated as a dividend includible in the gross income of a US Holder as ordinary income to the extent of our current and accumulated earnings and profits as determined under US federal income tax principles. Such dividends will not be eligible for the dividends received deduction allowed to corporations. To the extent the amount of such distribution exceeds our current and accumulated earnings and profits as so computed, the distribution will be treated first as a non-taxable return of capital to the extent of such US Holder s adjusted tax basis in the Offering Shares and, to the extent the amount of such distribution exceeds such adjusted tax basis, will be treated as gain from the sale of such shares. We do not expect to maintain calculations of earnings and profits for US federal income tax purposes. Therefore, a US Holder should expect that such distribution will generally be treated as a dividend. Dividends on the Offering Shares will not be eligible for the preferential income tax rate on qualified dividend income under US federal income tax law. Dividends on the Offering Shares generally will constitute income from sources outside the United States for foreign tax credit limitation purposes. The US dollar value of any distribution made by us in foreign currency must be calculated by reference to the exchange rate in effect on the date of receipt of such distribution by the US Holder, regardless of whether the foreign currency is in fact converted into US dollars. If the foreign currency so received is converted into US dollars on the date of receipt, such US Holder generally will not recognize foreign currency gain or loss on such conversion. If the foreign currency so received is not converted into US dollars on the date of receipt, such US Holder will have a basis in the foreign currency equal to its US dollar value on the date of receipt. Any gain on a subsequent conversion or other disposition of the foreign currency generally will be treated as ordinary income or loss to such US Holder and generally will be income or loss from sources within the United States for foreign tax credit limitation purposes. Sale or other disposition Subject to the PFIC rules discussed below, a US Holder generally will recognize gain or loss for US federal income tax purposes upon a sale or other disposition of its Offering Shares in an amount equal to the difference between the amount realized from such sale or disposition and the US Holder s adjusted tax basis in such Offering Shares, as determined in US dollars. Such gain or loss generally will be capital gain or loss and will be long-term capital gain (taxable at a reduced rate for non-corporate US Holders, such as individuals) or loss if, on the date of sale or disposition, such Offering Shares were held by such US Holder for more than one year. The deductibility of capital loss is subject to significant limitations. Such gain or loss realized generally will be treated as derived from US sources. A US Holder that receives foreign currency from a sale or disposition of Offering Shares generally will realize an amount equal to the US dollar value of the foreign currency on the date of sale or disposition or, if such US Holder is a cash basis or electing accrual basis taxpayer and the Offering Shares are treated as being traded on an established securities market for this purpose, the settlement date. If the Offering Shares are so treated and the foreign currency received is converted into US dollars on the settlement date, a cash basis or electing accrual basis US Holder generally will not recognize foreign currency gain or loss on the conversion. If the foreign currency received is not converted into US dollars on the settlement date, the US Holder will have a basis in the foreign currency equal to the US dollar value on the settlement date. Any gain or loss on a subsequent conversion or other disposition of the foreign currency generally will be treated as ordinary income or loss to such US Holder and generally will be income or loss from sources within the United States for foreign tax credit limitation purposes. Passive foreign investment company rules In general, a corporation organised or incorporated outside the United States is a PFIC in any taxable year in which, after taking into account the income and assets of certain subsidiaries, either (i) at least 75.0% of its gross income is classified as passive income or (ii) at least 50.0% of the average quarterly value attributable to its assets produce or are held for the production of passive income. Passive income for this purpose generally includes dividends, interest, royalties, rents and gains from commodities and securities transactions. 183

5 Based on the present nature of our activities, including the planned Offering, and the present composition of our assets and sources of income, we believe that there is significant likelihood that we were a PFIC for the year ending on December 31, 2008 and we expect to be a PFIC for the year ending on December 31, If we are classified as a PFIC in any year that a US Holder is a shareholder, we generally will continue to be treated as a PFIC for that US Holder in all succeeding years, regardless of whether we continue to meet the income or asset test described above. If a US Holder does not make a valid election as discussed below, and we are a PFIC for any taxable year during which an investor is a US Holder, the investor will be subject to special tax rules with respect to any excess distribution received and any gain realized from a sale or other disposition (including a pledge) of Offering Shares. Distributions received in a taxable year that are greater than 125.0% of the average annual distributions received during the shorter of the three preceding taxable years or the US Holder s holding period for the Offering Shares will be treated as excess distributions. Under these special tax rules, (i) the excess distribution or gain will be allocated rateably over the US Holder s holding period for the Offering Shares; (ii) the amount allocated to the current taxable year will be treated as ordinary income; and (iii) the amount allocated to each other year will be subject to tax at the highest tax rate in effect for that year and an interest charge (at the rate generally applicable to underpayments of tax for the period from such year to the current year) will be imposed on the resulting tax attributable to each such year. A US Holder will generally be subject to similar rules with respect to distributions to us by, and dispositions by us of the stock of, any of our direct or indirect subsidiaries that are also PFICs ( lowertier PFICs ). A US Holder subject to the PFIC rules discussed above or below is required to file IRS Form 8621 with respect to its investment in the Offering Shares. US Holders should consult their own tax advisers concerning the potential applicability of other reporting requirements with respect to their investment in a PFIC. Mark-to-market election As an alternative to the application of the PFIC rules discussed above, a US Holder may make an election to include gain or loss on the Offering Shares as ordinary income or loss under a mark-to-market method, provided that the Offering Shares are regularly traded on a qualified exchange. A foreign stock exchange will be a qualified stock exchange if (i) it is regulated or supervised by a governmental authority of the country in which it is located; (ii) it has trading volume, listing, financial disclosure, surveillance and other requirements designed to prevent fraudulent and manipulative acts and practices, remove impediments to, and perfect the mechanism of, a free and open, fair and orderly, market, and to protect investors; (iii) the laws of the country in which the exchange is located and the rules of the exchange ensure that these requirements are actually enforced; and (iv) the rules of the exchange effectively promote active trading of listed stocks. Application has been made for the Shares to be admitted to SGX- ST. No assurance can be given that SGX-ST will be a qualified exchange or that the Offering Shares will be regularly traded for purposes of the mark-to-market election. If a US Holder makes an effective mark-to-market election, the US Holder will include in each year as ordinary income the excess of the fair market value of its Offering Shares at the end of the year over its adjusted tax basis in the Offering Shares. The US Holder will be entitled to deduct as an ordinary loss each year the excess of its adjusted tax basis in the Offering Shares over their fair market value at the end of the year, but only to the extent of the net amount previously included in income as a result of the mark-to-market election. A US Holder s adjusted tax basis in the Offering Shares will be increased by the amount of any income inclusion and decreased by the amount of any deductions under the mark-to-market rules. In addition, gains from an actual sale or other disposition of Offering Shares will be treated as ordinary income, and any losses will be treated as ordinary losses to the extent of any mark-to-market gains for prior years. If a US Holder makes a mark-to-market election, it will be effective for the taxable year for which the election is made and all subsequent taxable years unless the Offering Shares are no longer regularly traded on a qualified exchange or the IRS consents to the revocation of the election. A mark-to-market election with respect to the Offering Shares would not apply to a lower-tier PFIC (as defined above), and a US Holder would not be able to make such a mark-to-market election in respect of its indirect ownership interest in that lower-tier PFIC. Consequently, US holders could be subject to the PFIC rules with respect to income of, and gains on, the lower-tier PFIC the value of which already had been taken into account indirectly through mark-to-market adjustments. US Holders are urged to consult their own tax advisers regarding the issues raised by lower-tier PFICs. 184

6 Qualified electing fund election As an alternative to the application of the PFIC rules discussed above, a US investor may make an election to treat the PFIC as a qualified electing fund ( QEF ) for US federal income tax purposes. To make a QEF election, the PFIC must provide US investors with information compiled according to US federal income tax principles. We currently do not intend to compile such information for US Holders, and therefore it is expected that this election will be unavailable. US information reporting and backup withholding tax A US Holder may be subject to information reporting unless it establishes that payments to it are exempt from these rules. For example, payments to corporations generally are exempt from information reporting and backup withholding. Payments that are subject to information reporting may be subject to backup withholding if a US Holder does not provide its taxpayer identification number and otherwise comply with the backup withholding rules. Backup withholding is not an additional tax. Amounts withheld under the backup withholding rules are available to be credited against a US Holder s US federal income tax liability and may be refunded to the extent they exceed such liability, provided the required information is timely provided to the IRS. Under US federal income tax law and regulations, certain categories of US persons must file information returns with respect to their investment in the equity interests of a foreign corporation. A US person that purchases for cash Offering Shares will be required to file IRS Form 926 or similar form if the transfer, when aggregated with all transfers made by such person (or any related person) within the preceding 12 month period, exceeds US$100,000. In the event a US Holder fails to file any such required form, the US Holder could be required to pay a penalty equal to 10.0% of the gross amount paid for such Offering Shares up to a maximum penalty of US$100,000. The above description is not intended to constitute a complete analysis of all tax consequences relating to ownership of Offering Shares. Prospective investors should consult their own tax advisers concerning the tax consequences of their particular situations. 185

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