Singapore Ruling on Treatment of Subordinated Perpetual Securities Issued by a Singapore-Listed REIT Trustee

The Inland Revenue Authority of Singapore has published Advance Ruling Summary No. 6/2026, which addresses whether subordinated perpetual securities issued by a Singapore-listed REIT trustee qualify as "debt securities" for tax purposes, allowing the issuer to claim tax deductions on distributions and enabling investors to benefit from Qualifying Debt Securities (QDS) tax concessions.

---

Advance Ruling Summary No. 6/2026

1. Subject:

Whether:

a. The subordinated perpetual securities …