Singapore legislation
Regulation 39
Regulation 39
Amounts taken into account in qualifying current tax expense
Subregulation 1
The qualifying current tax expense of a constituent entity of an MNE group for a financial year must be adjusted to take into account the adjustments in paragraph (2) (to the extent they were not already taken into account).
Subregulation 2
Those adjustments are —
add any positive amount (and subtract any negative amount) of covered taxes that would be (if not for regulation 11) reflected in the FANIL of the constituent entity for the financial year but which (if not for this regulation) is not reflected in the qualifying current tax expense of the constituent entity for the financial year;
add any amount of covered taxes paid by, and subtract any amount of covered taxes refunded to, the constituent entity in the financial year that relates to an uncertain tax position where the amount was excluded for a previous financial year; and
add any positive amount (and subtract any negative amount) of covered taxes recorded in the equity or other comprehensive income of the constituent entity for the financial year, relating to amounts taken into account in the GloBE income or loss of the constituent entity and that are subject to covered taxes under the law of the jurisdiction where the constituent entity is located.
Subregulation 3
In making the adjustments in paragraph (2), no amount of covered taxes may be taken into account more than once.