Multinational Enterprise (Minimum Tax) Act 2024 · s 29

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s 29Top‑up amount of MNE group

In this Part, the top‑up amount for an MNE group for a financial year is the sum of —

(a)

the top‑up amount of every constituent entity (not being a special entity) of the MNE group located in Singapore for the financial year;

(b)

the top‑up amount of every constituent entity of the MNE group (called in this Act a section 29(b) entity) that is —

(i)

a flow‑through entity established, formed, incorporated or registered under the laws of Singapore;

(ii)

not a responsible member as defined in section 13; and

(iii)

a reverse hybrid entity with respect to any of its income, expenditure, profit or loss;

(c)

the top‑up amount of every constituent entity of the MNE group that is a minority‑owned constituent entity (not being an investment entity or insurance investment entity) located in Singapore for the financial year; and

(d)

the top‑up amount of every joint venture or JV subsidiary that is treated as a constituent entity of the MNE group located in Singapore for the financial year.