§ 50C — Pooling of credits

50C.—(1) Where, for the year of assessment 2012 or a subsequent year of assessment, a person is entitled to 2 or more tax credits under any other provision of this Part, the person may elect to be given a pooled credit for that year of assessment in lieu of any 2 or more of those credits (called in this section the replaced credits).(2) Subsection (1) only applies if the income that is the subject of each replaced credit (called in this section the elected income) satisfies all of the following conditions:(a)

tax under the law of the territory from which the income is derived that is of a similar character to income tax (by whatever name called) or qualified domestic minimum top‑up tax (but disregarding any excluded top‑up tax), has been paid on the income;[Act 36 of 2024 wef 20/03/2025]

(b)

at the time the income is received in Singapore by the person, the highest rate of tax of a similar character to income tax (by whatever name called) (but disregarding any excluded top‑up tax or qualified domestic minimum top‑up tax), levied under the law of that territory on any gains or profits from any trade or business carried on by a company in that territory at that time, is not less than 15%;[Act 36 of 2024 wef 20/03/2025]

(c)

the income tax payable under this Act on the income for the year of assessment (before allowance of any credit under this Part) is not nil.

(3) The total amount of the income tax chargeable to the person in respect of all the elected income is reduced by the amount of the pooled credit.

(4) The amount of the pooled credit is the lower of —(a)

the aggregate of the income tax chargeable for the year of assessment on all the elected income; and

(b)

the aggregate of the taxes paid on all the elected income in the territory or territories outside Singapore from which the elected income is derived.

(5) In subsection (4)(a), the aggregate of the income tax chargeable for the year of assessment on all the elected income is ascertained by —(a)

computing the amount of the income that is the subject of each replaced credit in accordance with the provisions of this Act, and then charging it to income tax at a rate ascertained by dividing the income tax chargeable (before allowance of any credit under this Part) on the assessable income of the person by the amount of the person’s assessable income; and

(b)

aggregating the amounts computed in accordance with paragraph (a) of all the replaced credits.

(6) Sections 50(5), (6), (9), (10), (11), (11A), (11B) and (12), 50A(2), 50B(2) and 50BA(2) apply, with the necessary modifications, for the purposes of this section.[32/2019; 27/2021]

[Act 30 of 2023 wef 30/10/2023]

(7) To avoid doubt, sections 50, 50A, 50B and 50BA (as applicable) continue to apply to any income that is the subject of a credit allowed under any other provision of this Part for which no election under this section is made.[Act 30 of 2023 wef 30/10/2023]

—(1) Where, for the year of assessment 2012 or a subsequent year of assessment, a person is entitled to 2 or more tax credits under any other provision of this Part, the person may elect to be given a pooled credit for that year of assessment in lieu of any 2 or more of those credits (called in this section the replaced credits).

(2) Subsection (1) only applies if the income that is the subject of each replaced credit (called in this section the elected income) satisfies all of the following conditions:(a)

tax under the law of the territory from which the income is derived that is of a similar character to income tax (by whatever name called) or qualified domestic minimum top‑up tax (but disregarding any excluded top‑up tax), has been paid on the income;[Act 36 of 2024 wef 20/03/2025]

(b)

at the time the income is received in Singapore by the person, the highest rate of tax of a similar character to income tax (by whatever name called) (but disregarding any excluded top‑up tax or qualified domestic minimum top‑up tax), levied under the law of that territory on any gains or profits from any trade or business carried on by a company in that territory at that time, is not less than 15%;[Act 36 of 2024 wef 20/03/2025]

(c)

the income tax payable under this Act on the income for the year of assessment (before allowance of any credit under this Part) is not nil.

(3) The total amount of the income tax chargeable to the person in respect of all the elected income is reduced by the amount of the pooled credit.

(4) The amount of the pooled credit is the lower of —(a)

the aggregate of the income tax chargeable for the year of assessment on all the elected income; and

(b)

the aggregate of the taxes paid on all the elected income in the territory or territories outside Singapore from which the elected income is derived.

(5) In subsection (4)(a), the aggregate of the income tax chargeable for the year of assessment on all the elected income is ascertained by —(a)

computing the amount of the income that is the subject of each replaced credit in accordance with the provisions of this Act, and then charging it to income tax at a rate ascertained by dividing the income tax chargeable (before allowance of any credit under this Part) on the assessable income of the person by the amount of the person’s assessable income; and

(b)

aggregating the amounts computed in accordance with paragraph (a) of all the replaced credits.

(6) Sections 50(5), (6), (9), (10), (11), (11A), (11B) and (12), 50A(2), 50B(2) and 50BA(2) apply, with the necessary modifications, for the purposes of this section.[32/2019; 27/2021]

[Act 30 of 2023 wef 30/10/2023]

(7) To avoid doubt, sections 50, 50A, 50B and 50BA (as applicable) continue to apply to any income that is the subject of a credit allowed under any other provision of this Part for which no election under this section is made.[Act 30 of 2023 wef 30/10/2023]