The Inland Revenue Authority of Singapore has published Advance Ruling Summary No. 5/2024 on the characterization of hybrid instruments and related issues. --- Advance Ruling Summary No. 5/2024 1. Subject: Whether: a. The subordinated perpetual securities (the "Securities") will be regarded as "debt securities" for the purpose of Section 43H(4) of the Income Tax Act 1947 ("ITA") and Regulation 2 of the Income Tax (Qualifying Debt Securities) Regulations ("QDS Regulations"); b. The Distributions payable on the Securities (including Arrears of Distribution and any Additional Distribution Amounts) (capitalised terms defined below) will be regarded as interest payable on indebtedness and eligible...