Clause 6

Any distribution that is liable to be made in respect of an AT1 instrument in the basis period for the year of assessment 2015 or a subsequent year of assessment shall be deemed for the purposes of this Act, and for that year of assessment, as interest derived from a debt security.(2) In this section —“AT1 instrument” means a security (not being shares) commonly known as Additional Tier 1 capital instrument which —

is issued in Singapore but not through a branch situated outside Singapore; and

either —

according to MAS Notice 637, may be used to satisfy the capital adequacy requirement of a bank incorporated in Singapore with a full banking licence, under section 10(2) of the Banking Act (Cap. 19); or

according to a direction issued under section 28(3) of the Monetary Authority of Singapore Act (Cap. 186) and MAS Notice 637, may be used to satisfy the capital adequacy requirement of any other financial institution within the meaning of section 27A(6) of that Act;“full banking licence” has the same meaning as in the Banking (Licence Fees) Notification (Cap. 19, N 1);“MAS Notice 637” means the notice commonly known as MAS Notice 637 that is issued by the Monetary Authority of Singapore pursuant to sections 10(2), 36(2) and 55 of the Banking Act, and includes any notice that replaces it.”.