Regulation 49

where a constituent entity located in Singapore is a permanent establishment, any qualifying current tax expense or qualifying deferred tax expense of its main entity located outside Singapore in respect of the income of that constituent entity must not be allocated to that constituent entity;

where a constituent entity located in Singapore is a controlled foreign company under a controlled foreign company tax regime, any qualifying current tax expense or qualifying deferred tax expense arising under that regime must not be allocated to that constituent entity;

where a constituent entity located in Singapore (X) makes a distribution (including any deemed distribution in respect of undistributed earnings or capital) to another constituent entity located outside Singapore (Y), any qualifying current tax expense or qualifying deferred tax expense of Y in respect of that distribution (other than withholding tax imposed by the ITA in respect of that distribution) must not be allocated to X; (d)where a constituent entity located in Singapore (X) is a hybrid entity with respect to any of its income, expenditure, profit or loss attributable to an ownership interest in X held by another constituent entity of the MNE group located outside Singapore (Y), and Y is subject to taxation on the income of X, any qualifying current tax expense or qualifying deferred tax expense of Y in respect of the income of X (other than that recorded in the financial accounts of Y and which arose from tax imposed by the ITA in respect of that income) must not be allocated to X;

where —

a constituent entity located in Singapore (X) is a reverse hybrid entity with respect to any of its income, expenditure, profit or loss attributable to another constituent entity of the MNE group located outside Singapore that is its reference entity (Y1); and (ii)Y1 or another constituent entity of the MNE group located outside Singapore that holds an indirect ownership interest in X through Y1 (Y2) is subject to taxation on the income of X,any qualifying current tax expense or qualifying deferred tax expense of Y1 or Y2 in respect of the income of X (other than that recorded in the financial accounts of Y1 or Y2 and which arose from tax imposed by the ITA in respect of that income) must not be allocated to X; and

where —

a constituent entity is a section 29(b) entity (X) with respect to any of its income, expenditure, profit or loss attributable to another constituent entity of the MNE group located outside Singapore that is its reference entity (Y1); and (ii)Y1 or another constituent entity of the MNE group located outside Singapore that holds an indirect ownership interest in X through Y1 (Y2) is subject to taxation on the income of X, any qualifying current tax expense or qualifying deferred tax expense of Y1 or Y2 in respect of the income of X (other than that recorded in the financial accounts of Y1 or Y2 and which arose from tax imposed by the ITA in respect of that income) must not be allocated to X.