Singapore - Income tax treatment of hybrid instruments 

June 5: The Inland Revenue Authority of Singapore (IRAS) in May 2014 issued a guide concerning the income tax treatment of hybrid instruments.

The guide describes factors that the Comptroller of Income Tax would consider in determining whether, for income tax purposes, such instruments are debt or equity instruments.

The guide also provides an opportunity for a Singapore-based issuer that intends to issue a hybrid instrument, to seek before issuing the instrument, an advance ruling from the IRAS on the characterization of the hybrid instrument. When a ruling has been obtained, the issuer is required to communicate that information to investors and prospective investors. Subsequently, an investor would be required to apply the appropriate tax treatment on any distributions received.

Read a May 2014 report [PDF 254 KB] prepared by the KPMG member firm in Singapore: Tax Alert

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