Singapore legislation
Regulation 60
Regulation 60
When transfer of controlling interest treated as acquisition and disposal of assets and liabilities
Subregulation 1
Where —
a controlling interest in a constituent entity of an MNE group is acquired or disposed of in a financial year;
that acquisition or disposal is treated in the same, or a similar manner, as a transfer of the assets and liabilities of that constituent entity —
where the constituent entity is a flow-through entity — under the law of the jurisdiction where the assets are located; or
in any other case — under the law of the jurisdiction where the constituent entity is located; and
that jurisdiction imposes a covered tax on the seller based on the gain (or deemed gain) on such transfer,that acquisition or disposal is to be treated as an acquisition or disposal of the assets and liabilities of that constituent entity, and regulation 59 does not apply to that acquisition or disposal.
Subregulation 2
Any covered tax described in paragraph (1)(c) is to be included in the qualifying current tax expense of the constituent entity referred to in paragraph (1) for that financial year.