SINGAPORE Law and Practice Contributed by: Doos Choi, Pierre Dzakpasu, Janelene Chen and Pieter de Ridder, Mayer Brown
4.2 Other Taxes, Duties, Charges or Tax Considerations There are nominal charges for registering certain types of security at the Accounting and Corpo - rate Regulatory Authority (ACRA) and the Land Titles Registry. There is also a nominal amount to be paid as stamp duty where security is taken over assets which relate to shares or land. 4.3 Tax Concerns for Foreign Lenders Interest paid to foreign private credit lenders is generally subject to 15% withholding tax in Sin - gapore, unless this is reduced as described in There are currently no specific tax incentives available for private credit lenders lending into Singapore unless their loans qualify as Qualify - ing Debt Securities (QDS) approved by MAS, which provides for a withholding tax exemption in Singapore on the interest due and payable under the loan(s). 4.5 Non-Bank Status Under Singapore’s tax treaties, interest paid to overseas non-bank lenders is generally subject to a higher withholding-tax rate compared with the withholding-tax rate on interest paid to bank lenders. 4.1 Withholding Tax . 4.4 Tax Incentives
case basis. Some or all of the junior tranche may be in the form of a convertible and/or carry an equity warrant. 3.8 Payment in Kind/Amortisation Private credit transactions in Asia are usually structured as bullet term loans. Whether there is any current pay will depend on the asset or business being financed, but payment-in-kind structures are regularly seen. 3.9 Call Protection Other than to say that call protection in some shape or form is a common feature, there is no universal market standard on call protection for private credit investments. The precise terms will be negotiated on a deal-by-deal basis. There is no withholding tax payable on prin - cipal repayments or interest payments under loans or notes in Singapore unless the lender is established outside the country, in which case the interest due and payable to the overseas lender is generally subject to 15% withholding tax. Exceptions apply if the borrowing qualifies as a Qualifying Debt Security or if the Singapore borrower enjoys a domestic withholding-tax exemption (eg, approved exempt funds, Finance and Treasury Centre or a shipping tax incentive). If the lender is tax resident in a jurisdiction which has a favourable double tax treaty with Singa - pore, the withholding rate may be reduced or eliminated provided that the lender is the ben - eficial owner of the interest. 4. Tax Considerations 4.1 Withholding Tax
5. Guarantees and Security 5.1 Assets and Forms of Security
The assets over which security can typically be taken and the relevant formalities and perfection requirements are discussed below. As a general note, in addition to any other secu - rity registration requirements set out below, if the security provider is a company incorporated in
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