Singapore legislation
Regulation 78
Regulation 78
Constituent entities eligible for QDMTT Safe Harbour
Subregulation 1
Every constituent entity of an MNE group (not being an entity mentioned in paragraph (3) or (4)) located in a jurisdiction is eligible for a GloBE Safe Harbour in this Division (called the Qualified Domestic Minimum Top‑Up Tax Safe Harbour or QDMTT Safe Harbour) for a financial year if —
the MNE group comes within the scope of the law of the jurisdiction that imposes a qualified domestic minimum top‑up tax for that financial year;
the qualified domestic minimum top-up tax is described in regulation 96, as one to which this regulation applies; and
none of the disqualifying conditions in regulation 80 apply for that financial year.
Subregulation 2
Every joint venture or JV subsidiary connected to an MNE group located in a jurisdiction is eligible for the QDMTT Safe Harbour for a financial year if —
the conditions in paragraph (1)(a) and (b) are satisfied; and
none of the disqualifying conditions in regulation 81 apply for that financial year.
Subregulation 3
Every constituent entity of an MNE group that is an investment entity or insurance investment entity located in a jurisdiction is eligible for the QDMTT Safe Harbour if —
the conditions in paragraph (1)(a) and (b) are satisfied; and
none of the disqualifying conditions in regulation 82 apply for that financial year.
Subregulation 4
Every constituent entity of an MNE group that is a minority‑owned constituent entity located in a jurisdiction is eligible for the QDMTT Safe Harbour if —
the conditions in paragraph (1)(a) and (b) are satisfied; and
none of the disqualifying conditions in regulation 83 apply for that financial year.