CapitaLand China Trust securities qualify for Singapore tax concessions
IRAS rules perpetual notes treated as debt.
CapitaLand China Trust said its $150m fixed-rate subordinated perpetual securities will qualify for Singapore tax concessions after the Inland Revenue Authority of Singapore ruled the instruments should be treated as debt securities.
The ruling applies to the securities issued under the trust’s $1b multicurrency debt issuance programme, according to an exchange filing.
CapitaLand said the tax ruling confirms that distributions payable on the securities, including optional distributions, will be regarded as interest on indebtedness under Singapore’s Income Tax Act.
As a result, the securities should qualify as qualifying debt securities, subject to the conditions set out in the trust’s information memorandum.
The ruling follows an application referenced in the pricing supplement issued in September 2025, which noted that CapitaLand had sought confirmation on whether holders could enjoy tax concessions available for qualifying debt securities.
The classification is based on filings made with the Monetary Authority of Singapore and the relevant tax regulations, the trust said.
CapitaLand advised holders to consult their own tax advisers on the tax implications that may apply in Singapore or other jurisdictions.