Perpetual Cumulative Subordinated Debt: Deferred Interest Payment and Deductibility

Income Tax Assessment Amendment Regulations 2011 (No. 2) were made on 10 March 2011 to ensure that payments to note holders made in respect of certain perpetual cumulative subordinated notes issued by banks, may still be tax deductible to the issuer despite the fact that returns on the notes are contingent on factors such as profitability, insolvency or negative earning conditions.