Singapore legislation
Regulation 44E
Regulation 44E
Divergence between GloBE and accounting values
Subregulation 1
This regulation applies where, because of the operation of any provision of the Act or these Regulations, the FANIL or GloBE income or loss of a constituent entity relating to an asset or liability is to be calculated based on a value (called the GloBE carrying value) which differs from the value of the asset or liability as recorded in the financial statements used to determine the FANIL or GloBE income or loss (called the accounting carrying value).
Subregulation 2
Unless otherwise expressly provided in the Act or these Regulations, for the purposes of determining the adjusted covered taxes of the constituent entity —
the GloBE carrying value is to be updated in accordance with the financial accounting standard used in determining the FANIL of the constituent entity; and
the deferred tax asset or deferred tax liability relating to that asset or liability is to be determined by reference to the GloBE carrying value (as updated, if applicable), and the qualifying deferred tax expense is to be adjusted accordingly.
Subregulation 3
No adjustment is to be made under paragraph (2)(a) to the GloBE carrying value of an asset for any impairment made to it.
Subregulation 4
Paragraph (3) does not apply in a case where the accounting carrying value of an asset after adjusting for impairment (called the post-adjustment accounting value) is less than its GloBE carrying value, and in such a case its GloBE carrying value is to be updated under paragraph (2)(a) to the post-adjustment accounting value for the purposes of paragraph (2).
Subregulation 5
To avoid doubt, and without limiting paragraph (2), paragraph (2) applies to any instance of divergence between the GloBE carrying value and the accounting carrying value for an asset or liability that results from the operation of regulation 21(3), 30(2), 31(2), 36(2) or 61(2)(a), (3) or (8).