Singapore legislation

Regulation 52

of Multinational Enterprise (Minimum Tax) Regulations 2024

Regulation 52

Exclusion from eligible payroll costs

Amended byS 860/2025 wef 31/12/2025S 860/2025 wef 31/12/2025S 860/2025 wef 31/12/2025

Subregulation 1

Amended byS 860/2025 wef 31/12/2025S 860/2025 wef 31/12/2025

For the purposes of section 18, the eligible payroll costs of a constituent entity of an MNE group for a financial year do not include —

(a)

the full amount of payroll costs of the constituent entity for that financial year that is directly attributable to its international shipping income for that financial year;

(b)

the full amount of payroll costs of the constituent entity for that financial year that is directly attributable to its ancillary international shipping income that is excluded from its FANIL for that financial year under regulation 25(1)(a) or (c);

(c)

the proportion of the payroll costs described in paragraph (2) of the constituent entity for that financial year that is only indirectly attributable to its international shipping income for that financial year; and

(d)

the proportion of the payroll costs described in paragraph (3) of the constituent entity for that financial year that is only indirectly attributable to its ancillary international shipping income that is excluded from its FANIL for that financial year under regulation 25(1)(a) or (c).

Subregulation 2

In paragraph (1)(c), the proportion of the payroll costs is that which the revenue of the constituent entity from international shipping activities for that financial year bears to its total revenue for that financial year.

Subregulation 3

Amended byS 860/2025 wef 31/12/2025

In paragraph (1)(d), the proportion of the payroll costs is that which the amount computed by the following formula bears to the total revenue of the constituent entity for that financial year:where —

(a)

A is the revenue of the constituent entity from ancillary international shipping activities for that financial year;

(b)

B is the amount of the ancillary international shipping income of the constituent entity that is excluded from its FANIL for that financial year under regulation 25(1)(a) or (c); and

(c)

C is the total amount of the ancillary international shipping income of the constituent entity for that financial year.