Discretionary non-cumulative securities
Published 1 April 2026, listed REIT trustee issues subordinated perpetuals, distributions semi-annually in arrears independent of profits. Issuer can omit/part-pay on notice; deferred amounts are non-cumulative and earn no interest. It can later pay optional amount up to unpaid distribution. No fixed redemption date but specified issuer options exist. Accounting treats instruments as equity under SFRS32. Proceeds may refinance borrowing/general working capital.
Payment stopper and winding-up ranking
Subject exceptions, unpaid scheduled distributions block issuer/REIT subsidiaries paying or redeeming/buying junior and non-pro-rata parity obligations. Block ends on all-securities redemption, next full distribution, full optional latest unpaid amount, or holder extraordinary-resolution permission. In winding up holders are treated like equal preferred REIT units, ahead of junior obligations but behind issuer creditors. These features must be assessed together rather than debt assumed from the name.
Debt,QDS and deduction timing
IRAS finds debt under 43H(4)/QDS regulation2; ordinary/optional distributions are interest on indebtedness and enjoy QDS benefits only with other requisite conditions.14(1)(a) deduction needs detailed proceeds tracing: capital employed earning issuer taxable income,14 rules met and no prohibition elsewhere. Deduct only legally due/payable, not scheduled distribution dates. Hybrid guide5 characterisation and 7/9 deduction/timing are referenced. Only applicant/transaction is bound and summary not updated for later law/interpretations.
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.
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