ESR-Logos Reit announces tax ruling on subordinated perpetual securities
The announcement was about the issue of $150m in an aggregate amount of 5.50%.
ESR-Logos Funds Management (S) Limited, as manager of ESR-Logos Reit has made an announcement regarding an issue of $150m in aggregate principal amount of 5.50% subordinated perpetual securities comprised in Series 008 pursuant to the $750m Multicurrency Debt Issuance Programme of RBC Investor Services Trust Singapore Limited.
According to the manager, in the pricing supplement dated 2 June 2022 issued in connection with the Series 008 Securities, references were made to an application to the Inland Revenue Authority of Singapore (IRAS) for an advance tax ruling to confirm the classification of the Series 008 Securities for Singapore income tax purposes and the Singapore tax treatment of the payment of the distributions
In particular, the IRAS has stated in the tax ruling that it is prepared to regard the Series 008 Securities as “debt securities” for the purpose of section 43H(4) of the Income Tax Act 1947 of Singapore and regulation 2 of the Income Tax (Qualifying Debt Securities) Regulations.
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Accordingly, the Distributions (including any Optional Distribution) due and payable on the Series 008 Securities will be regarded by the IRAS as interest payable on indebtedness. Subject to satisfying the governing conditions under the QDS Regulations, sections 43H, 13(2) and 13(16) of the ITA for qualifying debt securities (“QDS”), the Series 008 Securities will be regarded by the IRAS as QDS and the holders of the Series 008 Securities will be entitled to the tax concessions and exemptions under section 43H and section 13(1)(a) of the ITA, respectively.
“Unless otherwise defined herein, terms used in this announcement and which are defined in the terms and conditions of the Series 008 Securities read together with the Pricing Supplement shall bear the same meanings ascribed to them in the conditions,” ESR-Logos Reit manager said.