§ 30 — Top‑up amounts of constituent entities

30.—(1) This section applies for the purposes of determining under this Part the top‑up amounts of the entities in section 29.(2) Sections 16 to 21 apply to determine the top‑up amount of a constituent entity (not being a special entity) of the MNE group located in Singapore for the financial year with the necessary modifications and the following modifications:(a)

the reference to a jurisdiction is a reference to Singapore;

(b)

in section 16(4), K is nil;

(c)

in the definition of “carrying value” in section 18(4), the reference to the consolidated financial statements of the ultimate parent entity of the MNE group is, if paragraph 6(14) of the First Schedule applies, a reference to the financial statements of the constituent entity concerned;

(d)

such other modifications as may be prescribed by the regulations.

(2A) To avoid doubt, qualifying current tax expenses and qualifying deferred tax expenses that must not be allocated to the constituent entity because of any modifications mentioned in subsection (2)(d), must not in turn be allocated in accordance with sub-paragraph (5)(b), (c) or (d) of paragraph 1 of the First Schedule;[Act 25 of 2025 wef 01/01/2025]

(3) In a case where —(a)

a constituent entity (not being a special entity) of the MNE group located in Singapore (X) holds direct ownership interests in an investment entity or insurance investment entity located in a jurisdiction other than Singapore (Y); and

(b)

an election as described in section 24(17) is made by the filing entity of the MNE group in relation to Y,

then sections 16 to 21 apply under subsection (2) with the modifications set out in the regulations in section 24(17).

(4) Section 22 applies to determine the top‑up amount of a section 29(b) entity (X) with the following modifications:(a)

a reference to a stateless entity is a reference to X;

(b)

a reference to a jurisdiction in that section is a reference to Singapore;[Act 25 of 2025 wef 01/01/2025]

(c)

subsection (1A) of section 22 is omitted.[Act 25 of 2025 wef 01/01/2025]

(5) Section 23 applies to determine the top‑up amount of a minority‑owned constituent entity (not being an investment entity or insurance investment entity), as if the reference to a jurisdiction in that section were a reference to Singapore.

(6) Section 25 applies to determine the top‑up amount of a joint venture or JV subsidiary located in Singapore that is treated as a constituent entity of the MNE group located in Singapore.

(7) Without limiting subsection (6), paragraph 6(14) of the First Schedule applies to determine the top‑up amount for a financial year of —(a)

a standalone JV (X) located in Singapore; or

(b)

entities of a JV group (Ys) located in Singapore,

that are each treated as a constituent entity of an MNE group located in Singapore, as if —

(c)

a reference to all the constituent entities of an MNE group were to X or to Ys; and

(d)

a reference to the MNE group in paragraph 6(14)(a) of the First Schedule were to the MNE group to which X or Ys are connected.

(8) For the purposes of subsections (2) and (5), an election made by the filing entity of an MNE group in a GloBE information return (whether filed in Singapore or another jurisdiction) under section 18(9), 19(4), 20(1)(b) or 21(2) for a financial year, is treated as an election made under that provision as applied by subsection (2) or (5) (as the case may be) for that financial year.

(9) Regulations may be made under section 84 to apply the regulations mentioned in sections 16(7), 17(5), 18(11), 19(6) and 26 and paragraphs 1(2) and 6(2) of the First Schedule for the purpose of this Part with such modifications as may be specified in the regulations.

(10) Despite anything in this section, the top‑up amount of a constituent entity that is an investment entity or insurance investment entity is treated as nil.

—(1) This section applies for the purposes of determining under this Part the top‑up amounts of the entities in section 29.

(2) Sections 16 to 21 apply to determine the top‑up amount of a constituent entity (not being a special entity) of the MNE group located in Singapore for the financial year with the necessary modifications and the following modifications:(a)

the reference to a jurisdiction is a reference to Singapore;

(b)

in section 16(4), K is nil;

(c)

in the definition of “carrying value” in section 18(4), the reference to the consolidated financial statements of the ultimate parent entity of the MNE group is, if paragraph 6(14) of the First Schedule applies, a reference to the financial statements of the constituent entity concerned;

(d)

such other modifications as may be prescribed by the regulations.

(2A) To avoid doubt, qualifying current tax expenses and qualifying deferred tax expenses that must not be allocated to the constituent entity because of any modifications mentioned in subsection (2)(d), must not in turn be allocated in accordance with sub-paragraph (5)(b), (c) or (d) of paragraph 1 of the First Schedule;[Act 25 of 2025 wef 01/01/2025]

(3) In a case where —(a)

a constituent entity (not being a special entity) of the MNE group located in Singapore (X) holds direct ownership interests in an investment entity or insurance investment entity located in a jurisdiction other than Singapore (Y); and

(b)

an election as described in section 24(17) is made by the filing entity of the MNE group in relation to Y,

then sections 16 to 21 apply under subsection (2) with the modifications set out in the regulations in section 24(17).

(4) Section 22 applies to determine the top‑up amount of a section 29(b) entity (X) with the following modifications:(a)

a reference to a stateless entity is a reference to X;

(b)

a reference to a jurisdiction in that section is a reference to Singapore;[Act 25 of 2025 wef 01/01/2025]

(c)

subsection (1A) of section 22 is omitted.[Act 25 of 2025 wef 01/01/2025]

(5) Section 23 applies to determine the top‑up amount of a minority‑owned constituent entity (not being an investment entity or insurance investment entity), as if the reference to a jurisdiction in that section were a reference to Singapore.

(6) Section 25 applies to determine the top‑up amount of a joint venture or JV subsidiary located in Singapore that is treated as a constituent entity of the MNE group located in Singapore.

(7) Without limiting subsection (6), paragraph 6(14) of the First Schedule applies to determine the top‑up amount for a financial year of —(a)

a standalone JV (X) located in Singapore; or

(b)

entities of a JV group (Ys) located in Singapore,

that are each treated as a constituent entity of an MNE group located in Singapore, as if —

(c)

a reference to all the constituent entities of an MNE group were to X or to Ys; and

(d)

a reference to the MNE group in paragraph 6(14)(a) of the First Schedule were to the MNE group to which X or Ys are connected.

(8) For the purposes of subsections (2) and (5), an election made by the filing entity of an MNE group in a GloBE information return (whether filed in Singapore or another jurisdiction) under section 18(9), 19(4), 20(1)(b) or 21(2) for a financial year, is treated as an election made under that provision as applied by subsection (2) or (5) (as the case may be) for that financial year.

(9) Regulations may be made under section 84 to apply the regulations mentioned in sections 16(7), 17(5), 18(11), 19(6) and 26 and paragraphs 1(2) and 6(2) of the First Schedule for the purpose of this Part with such modifications as may be specified in the regulations.

(10) Despite anything in this section, the top‑up amount of a constituent entity that is an investment entity or insurance investment entity is treated as nil.