Regulation 44D

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 treatment in this regulation applies to all the constituent entities of the MNE group located in a jurisdiction for a financial year.

Where an election under paragraph (1) is effective for a financial year, any qualifying deferred tax expense which must otherwise be allocated from any constituent entity (W) located in the jurisdiction to another constituent entity (X) pursuant to regulation 44(1), (4), (5) or (5A) must be excluded from the qualifying deferred tax expense of W and must not be allocated to X.

Where an election is effective under paragraph (1) for a financial year, any qualifying deferred tax expense of any constituent entity (Y) located in the jurisdiction which must otherwise be treated as the qualifying deferred tax expense of Y’s permanent establishment (Z) pursuant to paragraph 1(4) of the First Schedule to the Act, must not be so treated.

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 financial year or any of the subsequent 4 financial years, and any such election has no effect.