Notes and amended redemption terms
A Singapore-incorporated issuer had issued QDS due in year T. Under amended conditions it could redeem all, rather than only some, notes at 100+X% of principal plus accrued interest after giving the required notice. It exercised that option under the conditions, and redemption occurred after 15 February 2023. X and T are anonymised values.
The premium and questions
The call option premium was X% of principal. The applicant asked whether it was an early redemption fee and/or redemption premium under section 13(16), with QDS withholding treatment, holder concessions and the individual exemption. The listed provisions include sections 13(1)(ba), 13(1)(zk), 13(2F), 13(16), 43H and 45A(2B)(a), and the QDS Regulations.
The change from 15 February 2023
IRAS explained that the QDS qualifying-income scope was streamlined from that date: payments made by the QDS issuer on maturity redemption or early redemption are qualifying income. In this case redemption under the note conditions was early redemption, and the issuer paid a fee connected with it.
Classification and governing conditions
The call option premium was an early redemption fee and/or redemption premium within section 13(16). The resulting concessions remain subject to sections 43H and 13(2F) and the QDS Regulations, where applicable; the classification does not remove those requirements.
Holders and withholding tax
Holders could obtain sections 13(1)(ba) and 43H exemptions and concessions. The section 13(1)(zk) exemption applied to individuals except where income arose through a Singapore partnership or from carrying on a trade, business or profession in Singapore. Subject to the governing conditions, payment or deemed payment of the premium to non-resident holders was not subject to withholding tax under section 45A(2B)(a).
Publication date and scope
This summary explains the IRAS advance ruling published on 1 August 2025. The ruling binds the applicant and the specified transaction only. Another taxpayer cannot assume that a similar arrangement will receive identical treatment. IRAS does not revise published ruling summaries when legislation or its interpretation changes. The provision numbers and conclusions below describe this dated source.
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 ↗