Obligation Crédit Agricole SA 4.85% ( FR001400G5U4 ) en SGD

Crédit Agricole SA

100 % ⇌

France

FR001400G5U4 ( en SGD )

4.85% par an ( paiement annuel )

26/02/2033

Prospectus brochure de l'obligation Crédit Agricole FR001400G5U4 en SGD 4.85%, échéance 26/02/2033

250 000 SGD

500 000 000 SGD

27/08/2025 ( Dans 35 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 FR001400G5U4, paye un coupon de 4.85% par an.
Le paiement des coupons est annuel et la maturité de l'Obligation est le 26/02/2033

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 assumption that IRAS regards each tranche of the
Notes as "debt securities" for the purposes of the Income Tax Act 1947 of Singapore ("ITA") and that
distribution payments made under each tranche of the Notes will be regarded as interest payable on
indebtedness and holders thereof may therefore enjoy the tax concessions and exemptions available
for qualifying debt securities, provided that the conditions for the qualifying debt securities scheme are
satisfied.
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 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 22% prior to the year of assessment 2024, and will be increased to 24% from
the year of assessment 2024. 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:
(a) 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
(b) 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.
Following the Singapore Budget Statement 2023, it was announced that the scope of Specified Income under
the qualifying debt securities scheme will be streamlined and clarified such that it includes all payments in
relation to early redemption of a qualifying debt security. Further details will be provided by the MAS by 31
May 2023.

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 person (a) who directly or indirectly
controls A; (b) who is being controlled directly or indirectly by A; or (c) who, together with A, is directly
or indirectly 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.
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.