Obligation Crédit Agricole SA 3.95% ( FR0014009V14 ) en SGD

Crédit Agricole SA

100 % ⇌

France

FR0014009V14 ( en SGD )

3.95% par an ( paiement annuel )

21/07/2032

Prospectus brochure de l'obligation Crédit Agricole FR0014009V14 en SGD 3.95%, échéance 21/07/2032

250 000 SGD

250 000 000 SGD

22/01/2026 ( Dans 201 jours )

Crédit Agricole est un groupe bancaire coopératif français, présent à l'international, structuré autour de caisses régionales et proposant une large gamme de services financiers.

L'Obligation émise par Crédit Agricole SA ( France ) , en SGD, avec le code ISIN FR0014009V14, paye un coupon de 3.95% par an.
Le paiement des coupons est annuel et la maturité de l'Obligation est le 21/07/2032

TAXATION
The following "Singapore Taxation" section is supplemental to, and should be read in conjunction
with the Final Terms dated 20 April 2022 in relation to the Issue of SGD 250,000,000 Subordinated
Fixed Rate Resettable Notes due 22 July 2032 (the "Notes") issued by Crédit Agricole S.A. (the
"Issuer"). Capitalised terms which are not otherwise defined have the same meaning as defined
in the Base Prospectus dated 8 April 2022.
Singapore Taxation
The statements below are general in nature and are based on the laws (including certain aspects
of current tax laws in Singapore and administrative guidelines and circulars issued by the
Monetary Authority of Singapore ("MAS") and Inland Revenue Authority of Singapore ("IRAS"))
in force as at the date hereof and are subject to any changes in such laws, administrative
guidelines or circulars, or the interpretation of those laws, guidelines or circulars, occurring after
such date, which changes could be made on a retroactive basis. These laws, guidelines and
circulars are also subject to various interpretations and the relevant tax authorities or the courts
could later disagree with the explanations or conclusions set out below. Neither these statements
nor any other statements in this disclosure are intended or are to be regarded as advice on the
tax position of any holder of the Notes or of any person acquiring, selling or otherwise dealing
with the Notes or on any tax implications arising from the acquisition, sale or other dealings in
respect of the Notes. The statements made herein do not purport to be a comprehensive or
exhaustive description of all the tax considerations that may be relevant to a decision to subscribe
for, purchase, own or dispose of the Notes and do not purport to deal with the tax consequences
applicable to all categories of investors, some of which (such as dealers in securities or financial
institutions in Singapore which have been granted the relevant Financial Sector Incentive(s)) may
be subject to special rules or tax rates. Prospective holders of the Notes are advised to consult
their own professional tax advisers as to the Singapore or other tax consequences of the
acquisition, ownership of or disposal of the Notes, including, in particular, the effect of any foreign,
state or local tax laws to which they are subject. It is emphasised that none of the Issuer, the
Arranger, the Dealers and any other persons involved in the Programme or the issuance of the
Notes accepts responsibility for any tax effects or liabilities resulting from the subscription for,
purchase, holding or disposal of the Notes.
This tax disclosure has also been drafted on the basis that the Notes will be regarded as "debt
securities" under Singapore law.

Interest and Other Payments
Generally, interest and other payments derived by a holder of the Notes who is not resident in
Singapore and who does not have any permanent establishment in Singapore is not subject to
tax, as such income is likely to be regarded as arising from a source outside Singapore, given
that the Issuer is issuing the Notes outside Singapore and not through a branch or otherwise in
Singapore. However, even if such interest and payments are regarded as sourced in Singapore,
such interest and other payments may also be exempt from tax, including withholding of tax, if
the Notes qualify as "qualifying debt securities" as discussed below.

Subject to the following paragraphs, under Section 12(6) of the Income Tax Act 1947 ("ITA"), the
following payments are deemed to be derived from Singapore:
(a)
any interest, commission, fee or any other payment in connection with any loan or
indebtedness or with any arrangement, management, guarantee, or service
relating to any loan or indebtedness which is (i) borne, directly or indirectly, by a
person resident in Singapore or a permanent establishment in Singapore (except
in respect of any business carried on outside Singapore through a permanent
establishment outside Singapore or any immovable property situated outside
Singapore) or (ii) deductible against any income accruing in or derived from
Singapore; or
(b)
any income derived from loans where the funds provided by such loans are
brought into or used in Singapore.
Such payments, where made to a person not known to the paying party to be a resident in
Singapore for tax purposes, are generally subject to withholding tax in Singapore. The rate at
which tax is to be withheld for such payments (other than those subject to the 15% final
withholding tax described below) to non-resident persons (other than non-resident individuals) is
currently 17%. The applicable rate for non-resident individuals is currently 22%, and is proposed
to be increased to 24% from the year of assessment 2024 pursuant to the Singapore Budget
Statement 2022. However, if the payment is derived by a person not resident in Singapore
otherwise than from any trade, business, profession or vocation carried on or exercised by such
person in Singapore and is not effectively connected with any permanent establishment in
Singapore of that person, the payment is subject to a final withholding tax of 15%. The rate of 15%
may be reduced by applicable tax treaties.
However, certain Singapore-sourced investment income derived by individuals from financial
instruments is exempt from tax, including:
(i)
interest from debt securities derived on or after 1 January 2004;
(ii)
discount income (not including discount income arising from secondary trading) from debt
securities derived on or after 17 February 2006; and
(iii)
prepayment fee, redemption premium and break cost from debt securities derived on or
after 15 February 2007,
except where such income is derived through a partnership in Singapore or is derived from the
carrying on of a trade, business or profession in Singapore.
The terms "break cost", "prepayment fee" and "redemption premium" are defined in the ITA as
follows:
"break cost", in relation to debt securities and qualifying debt securities, means any fee payable
by the issuer of the securities on the early redemption of the securities, the amount of which is
determined by any loss or liability incurred by the holder of the securities in connection with such
redemption;

"prepayment fee", in relation to debt securities and qualifying debt securities, means any fee
payable by the issuer of the securities on the early redemption of the securities, the amount of
which is determined by the terms of the issuance of the securities; and
"redemption premium", in relation to debt securities and qualifying debt securities, means any
premium payable by the issuer of the securities on the redemption of the securities upon their
maturity.
References to "break cost", "prepayment fee" and "redemption premium" in this Singapore tax
disclosure have the same meaning as defined in the ITA.
In addition, if more than half of the Notes issued under a tranche of the Programme are distributed
by any or any combination of financial institutions in Singapore with the Financial Sector Incentive
(Bond Market), Financial Sector Incentive (Standard Tier) or Financial Sector Incentive (Capital
Market) tax incentives (as defined in the ITA), the tranche of the Notes issued under the
Programme would be "qualifying debt securities" for the purposes of the ITA, to which the following
treatments shall apply:
(i)
subject to certain prescribed conditions having been fulfilled (including the furnishing by
the Issuer, or such other person as the MAS may direct, to the MAS of a return on debt
securities in respect of the Notes in the prescribed format within such period as the MAS
may specify and such other particulars in connection with the Notes as the MAS may
require, and the inclusion by the Issuer in all offering documents relating to the Notes of a
statement to the effect that where interest, discount income, prepayment fee, redemption
premium or break cost from the Notes is derived by a person who is not resident in
Singapore and who carries on any operation in Singapore through a permanent
establishment in Singapore, the tax exemption for qualifying debt securities shall not apply
if the non-resident person acquires the Notes using the funds and profits of such person's
operations through the Singapore permanent establishment), interest, discount income
(not including discount income arising from secondary trading), prepayment fee,
redemption premium and break cost (collectively, the "Specified Income") from the Notes
paid by the Issuer and derived by a holder who is not resident in Singapore and who (aa)
does not have any permanent establishment in Singapore or (bb) carries on any operation
in Singapore through a permanent establishment in Singapore but the funds used by that
person to acquire the Notes are not obtained from such person's operation through a
permanent establishment in Singapore, are exempt from Singapore income tax;
(ii)
subject to certain conditions having been fulfilled (including the furnishing by the Issuer,
or such other person as the MAS may direct, to the MAS of a return on debt securities in
respect of the Notes in the prescribed format within such period as the MAS may specify
and such other particulars in connection with the Notes as the MAS may require),
Specified Income from the Notes derived by any company or body of persons (as defined
in the ITA) in Singapore, other than any non-resident who qualifies for the tax exemption
as described in paragraph (i) above, is subject to income tax at a concessionary rate of
10% (except for holders of the relevant Financial Sector Incentive(s) who may be taxed at
different rates); and

(iii)
subject to:
(aa)
the Issuer including in all offering documents relating to the Notes a statement to
the effect that any person whose interest, discount income, prepayment fee,
redemption premium or break cost (i.e. the Specified Income) derived from the
Notes is not exempt from tax shall include such income in a return of income made
under the ITA; and
(bb)
the Issuer, or such other person as the MAS may direct, furnishing to the MAS a
return on debt securities in respect of the Notes in the prescribed format within
such period as the MAS may specify and such other particulars in connection with
the Notes as the MAS may require,
payments of Specified Income derived from the Notes are not subject to withholding of tax
by the Issuer.
However, notwithstanding the foregoing:
(A)
if during the primary launch of any tranche of Notes, the Notes of such tranche are issued
to fewer than four (4) persons and 50% or more of the issue of such Notes is beneficially
held or funded, directly or indirectly, by related parties of the Issuer, such Notes would not
qualify as "qualifying debt securities"; and
(B)
even though a particular tranche of Notes are "qualifying debt securities", if, at any time
during the tenure of such tranche of Notes, 50% or more of the issue of such Notes which
are outstanding at any time during the life of their issue is beneficially held or funded,
directly or indirectly, by any related party(ies) of the Issuer, Specified Income derived from
such Notes held by:
(i)
any related party of the Issuer; or
(ii)
any other person where the funds used by such person to acquire such Notes are
obtained, directly or indirectly, from any related party of the Issuer,
shall not be eligible for the tax exemption or concessionary rate of tax as described above.
The term "related party", in relation to a person (A), means any other person who, directly or
indirectly, controls A, or is controlled, directly or indirectly, by A, or where A and that other person,
directly or indirectly, are under the control of a common person.
Where interest, discount income, prepayment fee, redemption premium or break cost (i.e. the
Specified Income) is derived from the Notes by any person who is not resident in Singapore and
who carries on any operations in Singapore through a permanent establishment in Singapore, the
tax exemption available for qualifying debt securities under the ITA (as mentioned above) shall
not apply if such person acquires such Notes using the funds and profits of such person's
operations through a permanent establishment in Singapore. Notwithstanding that the Issuer is
permitted to make payments of Specified Income in respect of the Notes without deduction or
withholding of tax under Section 45 or Section 45A of the ITA, any person whose Specified Income
(whether it is interest, discount income, prepayment fee, redemption premium or break cost)
derived from the Notes is not exempt from tax is required to include such income in a return of
income made under the ITA.

Each of DBS Bank Ltd. and Oversea-Chinese Banking Corporation Limited is a Joint Lead
Manager for the Notes and a financial sector incentive (capital market) or financial sector incentive
(standard tier) company, for the purposes of the ITA.
Capital Gains
Any gains considered to be in the nature of capital made from the sale of the Notes will not be
taxable in Singapore. However, any gains derived by any person from the sale of the Notes which
are gains from any trade, business, profession or vocation carried on by that person, if accruing
in or derived from Singapore, may be taxable as such gains are considered revenue in nature.
There are no specific laws or regulations which deal with the characterisation of capital gains.
The characterisation of the gains arising from a sale of the Notes will depend on the individual
facts and circumstances of the holder relating to the sale of the Notes.
Holders of the Notes who apply or who are required to apply Singapore Financial Reporting
Standard 39 Financial Instruments: Recognition and Measurement ("FRS 39"), Singapore
Financial Reporting Standard 109 Financial Instruments ("FRS 109") or Singapore Financial
Reporting Standard (International) 9 ("SFRS(I) 9") (as the case may be), may for Singapore
income tax purposes be required to recognise gains or losses (not being gains or losses in the
nature of capital) on the Notes, irrespective of disposal, for tax purposes in accordance with the
provisions of FRS 39, FRS 109 or SFRS(I) 9 (as the case may be) (as modified by the applicable
provisions of Singapore income tax law) even though no sale or disposal of the Notes is made.
Please see the section below on "Adoption of FRS 39, FRS 109 or SFRS(I) 9 treatment for
Singapore income tax purposes".
Adoption of FRS 39, FRS 109 or SFRS(I) 9 Treatment for Singapore Income Tax Purposes
Section 34A of the ITA provides for the tax treatment for financial instruments in accordance with
FRS 39 (subject to certain exceptions and "opt-out" provisions) to taxpayers who are required to
comply with FRS 39 for financial reporting purposes. The IRAS has also issued an e-tax guide
entitled "Income Tax Implications Arising from the Adoption of FRS 39 Financial Instruments:
Recognition and Measurement".
FRS 109 or SFRS(I) 9 (as the case may be) is mandatorily effective for annual periods beginning
on or after 1 January 2018, replacing FRS 39. Section 34AA of the ITA requires taxpayers who
comply or who are required to comply with FRS 109 or SFRS(I) 9 for financial reporting purposes
to calculate their profit, loss or expense for Singapore income tax purposes in respect of financial
instruments in accordance with FRS 109 or SFRS(I) 9 (as the case may be), subject to certain
exceptions. The IRAS has also issued an e-tax guide entitled "Income Tax: Income Tax Treatment
Arising from Adoption of FRS 109 - Financial Instruments".
Holders of the Notes who may be subject to the tax treatment under sections 34A or 34AA of the
ITA should consult their own accounting and tax advisers regarding the Singapore income tax
consequences of their acquisition, holding or disposal of the Notes.
Estate Duty
Singapore estate duty has been abolished with respect to all deaths occurring on or after 15
February 2008.