The Inland Revenue Authority of Singapore has published Advance Ruling Summary No. 4/2021 and Advance Ruling Summary No. 5/2021, concerning the characterization of hybrid instruments and related issues. The rulings address questions regarding the characterization of subordinated perpetual securities and guaranteed senior perpetual capital securities as debt securities for the purpose of section 43N(4) of the Income Tax Act (ITA) and Regulation 2 of the Income Tax (Qualifying Debt Securities) Regulations (QDS Regulations). The rulings also address questions regarding whether distributions from such securities would be regarded as interest payable on indebtedness and eligible for the tax concessions and exemptions...