Singapore Publishes Ruling Summary on the Characterization of Hybrid Instruments and Related Issues for Securities Issued by a REIT

The Inland Revenue Authority of Singapore has published Advance Ruling Summary No. 8/2021, concerning the characterization of hybrid instruments and related issues for securities issued by a real estate investment trust (REIT).

---

Advance Ruling Summary No. 8/2021

Subject:

Whether:

• The Fixed Rate Subordinated Perpetual Securities (the "Securities") will be regarded as "debt securities" for the purpose of Section 43N(4) of the Income Tax Act (Chapter 134, Revised Edition 2014) ("ITA"…