Singapore legislation
Regulation 3
of Multinational Enterprise (Minimum Tax) (Administrative Matters) Regulations 2025
Regulation 3
Conditions to be designated local GIR filing entity
Subregulation 1
Subject to regulation 5, for the purposes of section 33(1), the conditions that a constituent entity (X) of a registered MNE group must satisfy to be designated as the designated local GIR filing entity of the MNE group (called in this regulation the designate) are as follows:
the designate must be the ultimate parent entity of the MNE group that is located in Singapore and is not an excluded entity;
if sub‑paragraph (a) is not satisfied by any X, the designate must be an intermediate parent entity of the MNE group that —
is located in Singapore; (ii)is the parent entity of all the other constituent entities of the MNE group that are located in Singapore; and
is not an excluded entity;
if sub‑paragraphs (a) and (b) are not satisfied by any X, the designate must be a constituent entity of the MNE group that is —
a legal person located in Singapore; or (ii)a permanent establishment located in Singapore, being a branch of a foreign company that is —
part of the MNE group; and
registered under Division 2 of Part 11 of the Companies Act 1967; (d)if sub‑paragraphs (a), (b) and (c) are not satisfied by any X, the designate must be any other permanent establishment of the MNE group that is located in Singapore.
Subregulation 2
In the case of a multi‑parent group, only an entity —
that is treated under regulation 61B of the Multinational Enterprise (Minimum Tax) Regulations 2024 (G.N. No. S 1062/2024) as a constituent entity of the single MNE group that the multi‑parent group is treated as under that regulation; and (b)that satisfies the conditions under paragraph (1), may be designated as the designated local GIR filing entity of the single MNE group.