Regulation 15

an amalgamating company maintains its financial accounts in respect of any trade or business carried on by it in a functional currency other than Singapore dollar in accordance with financial reporting standards in Singapore; and

the amalgamating company has made an irrevocable election in writing of one of the two rates of exchanges under regulation 4(1) of the Income Tax (Functional Currency) Regulations 2004 (G.N. No. S 748/2004) for the purposes of converting the amounts referred to in regulation 2 of those Regulations denominated in Singapore dollar into an equivalent amount in a non-Singapore dollar functional currency,the rate of exchange so elected shall continue to be applicable to the amalgamated company until the amounts are fully utilised, as if the amalgamated company is the amalgamating company.

an amalgamating company ceases to exist on the date of amalgamation; and

the functional currency in which the amalgamating company maintained its accounts in respect of any trade or business carried on by it (referred to as the functional currency of the amalgamating company) differs from that of the amalgamated company (referred to as the functional currency of the amalgamated company),the rate of exchange between the 2 functional currencies on the date of amalgamation shall be used to convert into the functional currency of the amalgamated company —

any capital allowance, donation or loss of the amalgamating company remaining unabsorbed on the date of amalgamation which is denominated in the functional currency of the amalgamating company; and (ii)for the purpose of section 34C(8) and (10) of the Act, the residue of the value of any industrial building, structure, machinery or plant, or right of the amalgamating company referred to in section 16, 19, 19A, 19B, 19C or 19D of the Act which is denominated in the functional currency of the amalgamating company.