Singapore Advance Ruling on Characterization of Hybrid Instruments and Related Issues

The Inland Revenue Authority of Singapore has published Advance Ruling Summary No. 7/2024 on the characterization of hybrid instruments and related issues.

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Advance Ruling Summary No. 7/2024

1. Subject:

Whether:

a. The fixed rate subordinated perpetual securities (the "Securities") will be regarded as "debt securities" for the purpose of Sections 13(16) and 43H(4) of the Income Tax Act 1947 ("ITA") and Regulation 2 of the Income Tax (Qualifying Debt Securities) Regulations ("QDS R…