Income Tax Concessionary Rate Exemption Debt Securities Amendment
Summary
Singapore Ministry of Finance issued amendments to Income Tax Regulations on concessionary tax rates for debt securities income, consolidating definitions of key terms including 'early redemption fee', 'financial institution', 'qualifying debt securities', and 'redemption premium' by referencing section 13(16) of the Income Tax Act 1947. The amendments have retroactive effect with various provisions deemed effective from December 2021, February 2023, and January 2024.
What changed
The amendment modifies regulation 2 of the Income Tax (Concessionary Rate of Tax or Exemption for Income Derived from Debt Securities) Regulations (Rg 32) by replacing multiple definitions previously contained in the regulations with references to section 13(16) of the Income Tax Act. Specifically removed terms include 'break cost' and 'prepayment fee', while consolidating definitions for 'early redemption fee', 'financial institution', 'qualifying debt securities', and 'redemption premium' to be sourced from section 13(16). The amendments carry retroactive operation dates: Regulation 6 effective December 31, 2021; Regulations 2, 3(f) and 5(d) effective February 15, 2023; Regulations 3(a)-(h), 4, and 5(a)-(e) effective January 1, 2024.
Financial institutions, fund managers, and investors involved in Singapore debt securities should review their tax positions and compliance documentation to ensure alignment with the consolidated definitions under section 13(16) of the Income Tax Act. Entities that may have relied on prior regulatory definitions for 'break cost' or 'prepayment fee' should obtain updated legal or tax advice, as these terms are no longer separately defined under the concessionary tax regime. The retroactive effective dates mean entities should assess whether amended returns or filings are required for prior tax years.
What to do next
- Review debt securities documentation for alignment with consolidated definitions under section 13(16) of the Income Tax Act
- Assess whether retroactive effective dates require amended tax filings for prior periods
- Consult tax advisers regarding removal of 'break cost' and 'prepayment fee' definitions from concessionary tax regime
Source document (simplified)
Income Tax (Concessionary Rate of Tax or Exemption for Income Derived from Debt Securities) (Amendment) Regulations 2026 Status:
Published in Subsidiary Legislation Supplement
on 02 Apr 2026
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No. S 195
| Income Tax Act 1947 |
| Income Tax
(Concessionary Rate of Tax or Exemption for
Income Derived from Debt Securities)
(Amendment) Regulations 2026 |
| | In exercise of the powers conferred by section 43H of the Income Tax Act 1947, the Minister for Finance makes the following Regulations: | | In exercise of the powers conferred by section 43H of the Income Tax Act 1947, the Minister for Finance makes the following Regulations: |
| In exercise of the powers conferred by section 43H of the Income Tax Act 1947, the Minister for Finance makes the following Regulations: | |
| Citation and commencement |
| 1. —(1) These Regulations are the Income Tax (Concessionary Rate of Tax or Exemption for Income Derived from Debt Securities) (Amendment) Regulations 2026.
| (2) Regulation 6 is deemed to have come into operation on 31 December 2021. |
| (3) Regulations 2, 3(f) and 5(d) are deemed to have come into operation on 15 February 2023. |
| (4) Regulations 3(a) to (e), (g) and (h), 4 and 5(a), (b), (c) and (e) are deemed to have come into operation on 1 January 2024. | | (2) Regulation 6 is deemed to have come into operation on 31 December 2021. | (3) Regulations 2, 3(f) and 5(d) are deemed to have come into operation on 15 February 2023. | (4) Regulations 3(a) to (e), (g) and (h), 4 and 5(a), (b), (c) and (e) are deemed to have come into operation on 1 January 2024. |
| (2) Regulation 6 is deemed to have come into operation on 31 December 2021. | | | |
| (3) Regulations 2, 3(f) and 5(d) are deemed to have come into operation on 15 February 2023. | | | |
| (4) Regulations 3(a) to (e), (g) and (h), 4 and 5(a), (b), (c) and (e) are deemed to have come into operation on 1 January 2024. | | | |
| Amendment of regulation 2 |
| 2. In the Income Tax (Concessionary Rate of Tax or Exemption for Income Derived from Debt Securities) Regulations (Rg 32) (called in these Regulations the principal Regulations), in regulation 2, replace the definitions of “break cost”, “financial institution”, “prepayment fee”, “qualifying debt securities” and “redemption premium” with —
| \| “ “early redemption fee”, “financial institution”, “qualifying debt securities” and “redemption premium” have the meanings given by section 13(16) of the Act. ”. \| | “ “early redemption fee”, “financial institution”, “qualifying debt securities” and “redemption premium” have the meanings given by section 13(16) of the Act. ”. |
| “ “early redemption fee”, “financial institution”, “qualifying debt securities” and “redemption premium” have the meanings given by section 13(16) of the Act. ”. | | | | “ “early redemption fee”, “financial institution”, “qualifying debt securities” and “redemption premium” have the meanings given by section 13(16) of the Act. ”. | | “ “early redemption fee”, “financial institution”, “qualifying debt securities” and “redemption premium” have the meanings given by section 13(16) of the Act. ”. |
| | “ “early redemption fee”, “financial institution”, “qualifying debt securities” and “redemption premium” have the meanings given by section 13(16) of the Act. ”. | | “ “early redemption fee”, “financial institution”, “qualifying debt securities” and “redemption premium” have the meanings given by section 13(16) of the Act. ”. | |
| “ “early redemption fee”, “financial institution”, “qualifying debt securities” and “redemption premium” have the meanings given by section 13(16) of the Act. ”. | | |
| Amendment of regulation 3 |
| 3. In the principal Regulations, in regulation 3 —
| (a) | in paragraph (aa), replace “26th April 1999” wherever it appears with “26 April 1999”; |
| (b) | in paragraph (aa), replace “31st December 2023” with “31 December 2028 (both dates inclusive)”; |
| (c) | in paragraph (ab), delete sub-paragraph (i); |
| (d) | in paragraph (ab)(ii), replace “17th February 2006 to 31st December 2023” with “17 February 2006 to 31 December 2028 (both dates inclusive)”; |
| (e) | in paragraph (ac), replace “1st January 2005 to 31st December 2023” with “1 January 2005 to 31 December 2028 (both dates inclusive)”; |
| (f) | in sub-paragraph (ad), replace “break cost, prepayment fee” with “early redemption fee”; |
| (g) | in paragraph (ad), replace “15th February 2007” wherever it appears with “15 February 2007”; and |
| (h) | in paragraph (ad), replace “31st December 2023” with “31 December 2028 (both dates inclusive)”. | | (a) | in paragraph (aa), replace “26th April 1999” wherever it appears with “26 April 1999”; | (b) | in paragraph (aa), replace “31st December 2023” with “31 December 2028 (both dates inclusive)”; | (c) | in paragraph (ab), delete sub-paragraph (i); | (d) | in paragraph (ab)(ii), replace “17th February 2006 to 31st December 2023” with “17 February 2006 to 31 December 2028 (both dates inclusive)”; | (e) | in paragraph (ac), replace “1st January 2005 to 31st December 2023” with “1 January 2005 to 31 December 2028 (both dates inclusive)”; | (f) | in sub-paragraph (ad), replace “break cost, prepayment fee” with “early redemption fee”; | (g) | in paragraph (ad), replace “15th February 2007” wherever it appears with “15 February 2007”; and | (h) | in paragraph (ad), replace “31st December 2023” with “31 December 2028 (both dates inclusive)”. |
| (a) | in paragraph (aa), replace “26th April 1999” wherever it appears with “26 April 1999”; | | | | | | | | | | | | | | | |
| (b) | in paragraph (aa), replace “31st December 2023” with “31 December 2028 (both dates inclusive)”; | | | | | | | | | | | | | | | |
| (c) | in paragraph (ab), delete sub-paragraph (i); | | | | | | | | | | | | | | | |
| (d) | in paragraph (ab)(ii), replace “17th February 2006 to 31st December 2023” with “17 February 2006 to 31 December 2028 (both dates inclusive)”; | | | | | | | | | | | | | | | |
| (e) | in paragraph (ac), replace “1st January 2005 to 31st December 2023” with “1 January 2005 to 31 December 2028 (both dates inclusive)”; | | | | | | | | | | | | | | | |
| (f) | in sub-paragraph (ad), replace “break cost, prepayment fee” with “early redemption fee”; | | | | | | | | | | | | | | | |
| (g) | in paragraph (ad), replace “15th February 2007” wherever it appears with “15 February 2007”; and | | | | | | | | | | | | | | | |
| (h) | in paragraph (ad), replace “31st December 2023” with “31 December 2028 (both dates inclusive)”. | | | | | | | | | | | | | | | |
| Amendment of regulation 4 |
| 4. In the principal Regulations, in regulation 4(b), replace “27th February 1999 to 31st December 2023” with “27 February 1999 to 31 December 2028 (both dates inclusive)”. |
| Amendment of regulation 7 |
| 5. In the principal Regulations, in regulation 7 —
| (a) | in paragraph (1), replace “26th April 1999 to 31st December 2023” with “26 April 1999 to 31 December 2028 (both dates inclusive)”; |
| (b) | in paragraph (1A), replace “27th February 2004 to 31st December 2023” with “17 February 2006 to 31 December 2028 (both dates inclusive)”; |
| (c) | in paragraph (1B), replace “1st January 2005 to 31st December 2023” with “1 January 2005 to 31 December 2028 (both dates inclusive)”; |
| (d) | in paragraph (1C), replace “break cost, prepayment fee” with “early redemption fee”; and |
| (e) | in paragraph (1C), replace “15th February 2007 to 31st December 2023” with “15 February 2007 to 31 December 2028 (both dates inclusive)”. | | (a) | in paragraph (1), replace “26th April 1999 to 31st December 2023” with “26 April 1999 to 31 December 2028 (both dates inclusive)”; | (b) | in paragraph (1A), replace “27th February 2004 to 31st December 2023” with “17 February 2006 to 31 December 2028 (both dates inclusive)”; | (c) | in paragraph (1B), replace “1st January 2005 to 31st December 2023” with “1 January 2005 to 31 December 2028 (both dates inclusive)”; | (d) | in paragraph (1C), replace “break cost, prepayment fee” with “early redemption fee”; and | (e) | in paragraph (1C), replace “15th February 2007 to 31st December 2023” with “15 February 2007 to 31 December 2028 (both dates inclusive)”. |
| (a) | in paragraph (1), replace “26th April 1999 to 31st December 2023” with “26 April 1999 to 31 December 2028 (both dates inclusive)”; | | | | | | | | | |
| (b) | in paragraph (1A), replace “27th February 2004 to 31st December 2023” with “17 February 2006 to 31 December 2028 (both dates inclusive)”; | | | | | | | | | |
| (c) | in paragraph (1B), replace “1st January 2005 to 31st December 2023” with “1 January 2005 to 31 December 2028 (both dates inclusive)”; | | | | | | | | | |
| (d) | in paragraph (1C), replace “break cost, prepayment fee” with “early redemption fee”; and | | | | | | | | | |
| (e) | in paragraph (1C), replace “15th February 2007 to 31st December 2023” with “15 February 2007 to 31 December 2028 (both dates inclusive)”. | | | | | | | | | |
| Replacement of references relating to Act because of 2020 Revised Edition |
| 6. In the principal Regulations —
| (a) | in the following provisions, replace “section 43N” with “section 43H”:
\| Regulation 2, definitions of “debt securities”, “Islamic debt securities”, “primary dealer” and “Singapore Government securities” \|
\| Regulation 6(2); \| | Regulation 2, definitions of “debt securities”, “Islamic debt securities”, “primary dealer” and “Singapore Government securities” | Regulation 6(2); |
| Regulation 2, definitions of “debt securities”, “Islamic debt securities”, “primary dealer” and “Singapore Government securities” | | | |
| Regulation 6(2); | | | |
| (b) | in regulation 3(aa), (ab), (ac) and (ad), replace “section 43N(2)” with “section 43H(2)”; and | | |
| (c) | in regulation 6(2), replace “Section 37B” with “Section 37A”. | | | | (a) | in the following provisions, replace “section 43N” with “section 43H”:
| Regulation 2, definitions of “debt securities”, “Islamic debt securities”, “primary dealer” and “Singapore Government securities” |
| Regulation 6(2); | | Regulation 2, definitions of “debt securities”, “Islamic debt securities”, “primary dealer” and “Singapore Government securities” | Regulation 6(2); | (b) | in regulation 3(aa), (ab), (ac) and (ad), replace “section 43N(2)” with “section 43H(2)”; and | (c) | in regulation 6(2), replace “Section 37B” with “Section 37A”. |
| (a) | in the following provisions, replace “section 43N” with “section 43H”:
| Regulation 2, definitions of “debt securities”, “Islamic debt securities”, “primary dealer” and “Singapore Government securities” |
| Regulation 6(2); | | Regulation 2, definitions of “debt securities”, “Islamic debt securities”, “primary dealer” and “Singapore Government securities” | Regulation 6(2); | | | | | |
| Regulation 2, definitions of “debt securities”, “Islamic debt securities”, “primary dealer” and “Singapore Government securities” | | | | | | | | |
| Regulation 6(2); | | | | | | | | |
| (b) | in regulation 3(aa), (ab), (ac) and (ad), replace “section 43N(2)” with “section 43H(2)”; and | | | | | | | |
| (c) | in regulation 6(2), replace “Section 37B” with “Section 37A”. | | | | | | | |
[G.N. Nos. S 214/2001; S 349/2005; S 51/2006; S 98/2007; S 398/2008; S 267/2009; S 520/2013; S 239/2016; S 868/2018]
| | Made on 28 March 2026. |
| NGIAM SIEW YING |
Second Permanent Secretary,
Ministry of Finance,
Singapore. | Made on 28 March 2026. | NGIAM SIEW YING |
| Made on 28 March 2026. | | |
| NGIAM SIEW YING | | |
| [AG/LEGIS/SL/134/2020/91] |
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