Singapore legislation

Regulation 4C

of Multinational Enterprise (Minimum Tax) Regulations 2024

Regulation 4C

Application of section 8(1) after demerger of MNE group

Amended byS 860/2025 wef 31/12/2025S 129/2025 wef 25/02/2025

Subregulation 1

This regulation applies for the purposes of determining whether, in accordance with section 8, the Act applies for a financial year to an MNE group (called the demerged group) that results from a demerger.

Subregulation 2

Amended byS 860/2025 wef 31/12/2025

In this regulation —

Definition

“demerger” means an arrangement pursuant to which the entities of a relevant MNE group are separated into 2 or more groups such that the assets, liabilities, income, expenses and cash flows of those entities are no longer included in the consolidated financial statements of the same ultimate parent entity;

Definition

“FY1” means the first financial year of the demerged group after the effective date of the demerger;

Definition

“FY2” means the second financial year of the demerged group after the effective date of the demerger;

Definition

“FY3” means the third financial year of the demerged group after the effective date of the demerger;

Definition

“FY4” means the fourth financial year of the demerged group after the effective date of the demerger;

Definition

“relevant MNE group” means an MNE group to which —

(a)

the Act applies for its financial year in which the effective date of the demerger falls; or

(b)

a qualified IIR applies for its financial year that begins before 1 January 2025 in which the effective date of the demerger falls.

Amended byS 860/2025 wef 31/12/2025

Subregulation 3

Amended byS 129/2025 wef 25/02/2025

The Act applies to the demerged group for FY1, FY2, FY3 or FY4 —

(a)

in the case of FY1 — if the demerged group’s consolidated group revenue (determined by reference to the consolidated financial statements of its ultimate parent entity) for FY1 is equal to or exceeds the threshold in section 8(2);

(b)

in the case of FY2 — if the demerged group’s consolidated group revenue (determined by reference to the consolidated financial statements of its ultimate parent entity) for each of FY1 and FY2 is equal to or exceeds the threshold in section 8(2);

(c)

in the case of FY3 — if the demerged group’s consolidated group revenue (determined by reference to the consolidated financial statements of its ultimate parent entity) exceeds the threshold in section 8(2) for at least 2 of the following financial years:

(i)

FY1;

(ii)

FY2;

(iii)

FY3; or

(d)

in the case of FY4 — if the demerged group’s consolidated group revenue (determined by reference to the consolidated financial statements of its ultimate parent entity) exceeds the threshold in section 8(2) for at least 2 of the following financial years:

(i)

FY1;

(ii)

FY2;

(iii)

FY3;

(iv)

FY4.