Singapore legislation

Regulation 12C

of Income Tax (Amalgamation of Companies) Regulations 2011

Regulation 12C

Modification of section 37O of Act when target company is another amalgamating company which ceases to exist after amalgamation

Amended byS 170/2022 wef 31/12/2021S 170/2022 wef 01/04/2015S 170/2022 wef 31/12/2021

Subregulation 1

This regulation applies where —

(a)

before the amalgamation, an amalgamating company made a qualifying acquisition of ordinary shares in another company;

(b)

the target company is another amalgamating company and it ceases to exist upon the amalgamation; and

(c)

the amalgamating company mentioned in sub‑paragraph (a) continues in existence after the amalgamation as the amalgamated company.

Subregulation 2

Amended byS 170/2022 wef 31/12/2021

For the purpose of determining whether a deduction under section 37O of the Act may be made to the amalgamated company in respect of the expenditure for that acquisition of shares, the amalgamated company is not to be regarded as having divested of its shares in the target company for the purposes of section 37O(17)(c), (d) or (da) of the Act by virtue only of the operation of section 34C(7) of the Act (amalgamating company treated as having disposed of shares in another amalgamating company immediately before amalgamation).

Subregulation 3

Amended byS 170/2022 wef 01/04/2015S 170/2022 wef 31/12/2021

Where the qualifying acquisition mentioned in paragraph (1)(a) is an acquisition under section 37O(4A)(a) or (b) of the Act, the conditions in regulation 5A(1)(a) and (b) of the Share Acquisition Regulations must be satisfied in accordance with regulation 5(4) of those Regulations and up to the date immediately before the date of the amalgamation, but not thereafter.