Singapore legislation
Regulation 54
Regulation 54
Adjustment to substance-based income exclusion due to eligible employees performing activities in and outside constituent entity’s jurisdiction
If the percentage of the time spent (X%) by an eligible employee of a constituent entity of an MNE group in performing activities for the MNE group in the jurisdiction where the constituent entity is located for the financial year, is 50% or less of the total time spent by him or her in performing activities for the MNE group, then, for determining the payroll carve-out amount of a constituent entity for that financial year, the eligible payroll costs of the constituent entity for that financial year for that eligible employee is the product of —
the eligible payroll costs of the constituent entity for that financial year for that eligible employee as adjusted (if applicable) in accordance with section 18(5) and (6) and regulation 57; and
X%.