Singapore Advance Ruling on Tax Treatment of Tender Fees in Respect of Notes Accepted for Purchase by Issuer

The Inland Revenue Authority of Singapore has published Advance Ruling Summary No. 22/2025 on the tax treatment of tender fees in respect of notes accepted for purchase by the issuer.

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Advance Ruling Summary No. 22/2025

1. Subject:

Whether:

a. the amount of $X in excess of each $1,000 in principal amount of the Notes (defined below) in the computation of the Early Tender Offer Consideration (defined below) (the "Tender Fees") would be treated as "early redemption fee" and/or "rede…