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Singapore Advance Ruling on Characterisation of Redeemable Preference Shares and Related Issue

09 December 2022

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Approved Changes

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Singapore

The Inland Revenue Authority of Singapore has published Advance Ruling Summary No. 18/2022, concerning the characterisation of redeemable preference shares and related issue. --- Advance Ruling Summary No. 18/2022 Subject: Whether: Company A's preference shares are characterised as an equity instrument from a Singapore tax perspective; and the distributions payable by Company A on the preference shares will be regarded as dividends. Accordingly, the dividend payment should not be tax deductible to Company A and there should be no Singapore withholding tax on the payment. Relevant background and facts: Company A is a limited liability company incorporated in Singapore. The...