This Public Clarification addresses the Corporate Tax treatment of payments made by banks on Additional Tier 1 (AT1) Instruments issued to meet minimum regulatory capital requirements aligned with the Basel III framework. It sets out the criteria such instruments satisfy, including perpetuity, subordination, full discretion to cancel dividends or coupons, and payment out of distributable items. Applying Article 20 of the Corporate Tax Law, it confirms that where a payment on an AT1 Instrument accounted for as equity is not included in Accounting Income under IFRS, it is not deductible in determining Taxable Income. Holder-side classification and treatment remain outside its scope.