Regulation 33

The filing entity of an MNE group may make an election in a GloBE information return (whether filed in Singapore or in another jurisdiction) in accordance with the GloBE rules that the constituent entities of the MNE group that are located in the same jurisdiction and are included in a tax consolidation group are to apply the consolidated accounting treatment of the ultimate parent entity to eliminate income, expenses, gains and losses arising from transactions between those constituent entities.

Where an election under paragraph (1) is effective for a financial year, the FANIL for that financial year of each of those constituent entities must be adjusted accordingly.

Where an election is made under paragraph (1), the FANIL of the constituent entities to which the election applies must be adjusted in the first financial year for which the election has effect, to ensure that there are no duplications or omissions of items of income, expenses, gains or losses arising from the making of the election.

If the election is subsequently revoked, then, in the first financial year for which the election ceases to apply, the FANIL of the constituent entities to which the election applies must be adjusted to ensure that there are no duplications or omissions of items of income, expenses, gains or losses arising from the revocation of the election.

In paragraph (1), the constituent entities of an MNE group located in a jurisdiction are included in a tax consolidation group if, under the law of that jurisdiction, the income, expenses, gains or losses of those constituent entities may for tax purposes be aggregated, surrendered to each other or otherwise shared or transferred between them as a result of a connection between those constituent entities.

An election under paragraph (1) must not be revoked for the financial year for which it is made or for any of the subsequent 4 financial years, and any such revocation has no effect.

If an election under paragraph (1) is revoked for a financial year, another election under that paragraph must not be made (whether in Singapore or in another jurisdiction) in respect of the constituent entities located in that jurisdiction for that or any of the subsequent 4 financial years, and any such election has no effect.