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Taxes · PDF

Corporate Ruling 8/2025: Cash Tender Fees on Cancelled QDS Notes

Ruling 8/2025 considers the fixed cash excess paid on early tender and cancellation of QDS separately from accrued interest.

Source checked · 11 October 2026 · Document date: 2 Jun 2025 Advance ruling · case-specific

Tender, cancellation and settlement interest

Published 2 June 2025, Singapore issuer notes are QDS due in symbolic T+2. Its offer buys validly tendered/accepted notes for cash subject to offer conditions being satisfied or waived; every purchased note is retired and cancelled. Each $1,000 principal validly accepted by the early deadline receives $(1,000+X). Separately holders receive accrued/unpaid interest from the last interest payment up to, but excluding, the specified Year T settlement date. X is anonymised, not a disclosed standard fee.

Classification and three tax outcomes

Buying before maturity is early redemption; the X excess is the issuer’s fee/premium in connection with it. IRAS classifies it as early redemption fee and/or redemption premium under 13(16). Subject where applicable to all 13(2F)/43H and QDS Regulations conditions, holders can obtain 13(1)(ba)/43H concessions/exemptions, and individuals have 13(1)(zk) exemption except Singapore-partnership or Singapore trade/business/profession income. Paid/deemed-paid Tender Fees to non-residents are not subject to 45A(2B)(a) withholding.

Keep the specified payment separate

The decision concerns the tender excess and does not replace the treatment of separately accrued interest or dispense with QDS qualification. Only the applicant and specified transaction are bound and the summary is not updated for later tax-law or interpretation changes.

Official source

This article independently explains the substantive contents of the official PDF, including the relevant conditions, procedures and annexes. The linked document remains the authoritative source for its original wording, and later changes should be checked separately.

Read the official PDF ↗
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