§ 33 — Designated local GIR filing entity

33.—(1) A constituent entity located in Singapore of a registered MNE group that satisfies the conditions prescribed by the regulations, must be designated as the designated local GIR filing entity of the MNE group in accordance with subsection (2).(1A) In subsection (1), a constituent entity excludes a securitisation entity unless it is the only constituent entity of the MNE group located in Singapore.[Act 25 of 2025 wef 01/01/2025]

(2) The designation must be made —(a)

by any constituent entity of the MNE group located in Singapore, on behalf of the following entities (each called a represented entity of the MNE group):(i)

all the constituent entities located in Singapore of the MNE group;

(ii)

all joint ventures and JV subsidiaries located in Singapore and connected to the MNE group;

(iii)

all section 29(b) entities of the MNE group; and[Act 25 of 2025 wef 01/01/2025]

(b)

in the form and manner, and within the time, specified by the Comptroller.

(3) Where —(a)

a registered MNE group does not have a constituent entity mentioned in subsection (1);

(b)

subsection (1) (read with section 31(3)(a)) has not been complied with; or

(c)

the Comptroller registers an MNE group under section 32,

the Comptroller must deem a constituent entity of the MNE group located in Singapore, a joint venture or JV subsidiary located in Singapore and connected to the MNE group, or a section 29(b) entity of the MNE group, as the designated local GIR filing entity of that MNE group.

(3A) In subsection (3), a constituent entity excludes a securitisation entity unless it is the only constituent entity of the MNE group located in Singapore.[Act 25 of 2025 wef 01/01/2025]

(4) The Comptroller must give notice of such deeming, and the identity of the entity that has been so deemed, to the ultimate parent entity, and all entities known to the Comptroller to be represented entities of the MNE group.

(5) Within one month after the date of the notice in subsection (4) or such extended period as the Comptroller may allow, any constituent entity of the registered MNE group located in Singapore may, on behalf of all represented entities of the MNE group, apply to the Comptroller to designate another constituent entity located in Singapore as the designated local GIR filing entity of the MNE group in place of the deemed designated local GIR filing entity.

(6) An application under subsection (5) must be made in the form and manner specified by the Comptroller.

(7) Where, after an entity (X) has been designated or deemed as the designated local GIR filing entity of the MNE group, any of the following events occurs or is expected to occur:(a)

X is wound up or otherwise dissolved;

(b)

X is struck off a register kept under the Companies Act 1967 or the Limited Liability Partnerships Act 2005;

(c)

X ceases to be registered under the Business Names Registration Act 2014 or the Limited Partnerships Act 2008 or has its registration thereunder cancelled;

(d)

X ceases to be a part of or to be connected to the MNE group, as the case may be;

(e)

any other event prescribed by the regulations,

then another constituent entity of the MNE group located in Singapore must be designated as the designated local GIR filing entity of the MNE group in place of X, not later than one month after the occurrence of the event or such extended time as the Comptroller may allow, and in accordance with subsection (2).

(8) Subsections (3) to (6) apply with the necessary modifications to a failure to comply with subsection (7) as they apply to a failure to comply with subsection (1).

(9) Where, at any time after an entity (X) has been designated or deemed as the designated local GIR filing entity of the MNE group, the MNE group has a new constituent entity located in Singapore, then another constituent entity of the MNE group located in Singapore may be designated as the designated local GIR filing entity of the MNE group in place of X in accordance with subsection (2) —(a)

within 6 months after the end of the financial year in which the acquisition of ownership or control occurred that resulted in the MNE group having the new constituent entity; or

(b)

such extended time as the Comptroller may allow.

(10) The constituent entity that replaced X as the designated local GIR filing entity of an MNE group under subsection (7) or (9) must carry out any duty under this Act of a designated local GIR filing entity that has yet to be carried out by X on the date specified under subsection (11).

(11) The designation or deeming of an entity as a designated local GIR filing entity under this section takes effect from the date specified by —(a)

the constituent entity that made the designation on behalf of all the represented entities of the MNE group; or

(b)

the Comptroller,

as the case may be.

(12) Where an entity has been designated as a designated local GIR filing entity of a registered MNE group under this section, the Comptroller must notify the ultimate parent entity of the MNE group (if located in Singapore), and all other represented entities of the MNE group, of the identity of the designated local GIR filing entity.

—(1) A constituent entity located in Singapore of a registered MNE group that satisfies the conditions prescribed by the regulations, must be designated as the designated local GIR filing entity of the MNE group in accordance with subsection (2).

(1A) In subsection (1), a constituent entity excludes a securitisation entity unless it is the only constituent entity of the MNE group located in Singapore.[Act 25 of 2025 wef 01/01/2025]

(2) The designation must be made —(a)

by any constituent entity of the MNE group located in Singapore, on behalf of the following entities (each called a represented entity of the MNE group):(i)

all the constituent entities located in Singapore of the MNE group;

(ii)

all joint ventures and JV subsidiaries located in Singapore and connected to the MNE group;

(iii)

all section 29(b) entities of the MNE group; and[Act 25 of 2025 wef 01/01/2025]

(b)

in the form and manner, and within the time, specified by the Comptroller.

(3) Where —(a)

a registered MNE group does not have a constituent entity mentioned in subsection (1);

(b)

subsection (1) (read with section 31(3)(a)) has not been complied with; or

(c)

the Comptroller registers an MNE group under section 32,

the Comptroller must deem a constituent entity of the MNE group located in Singapore, a joint venture or JV subsidiary located in Singapore and connected to the MNE group, or a section 29(b) entity of the MNE group, as the designated local GIR filing entity of that MNE group.

(3A) In subsection (3), a constituent entity excludes a securitisation entity unless it is the only constituent entity of the MNE group located in Singapore.[Act 25 of 2025 wef 01/01/2025]

(4) The Comptroller must give notice of such deeming, and the identity of the entity that has been so deemed, to the ultimate parent entity, and all entities known to the Comptroller to be represented entities of the MNE group.

(5) Within one month after the date of the notice in subsection (4) or such extended period as the Comptroller may allow, any constituent entity of the registered MNE group located in Singapore may, on behalf of all represented entities of the MNE group, apply to the Comptroller to designate another constituent entity located in Singapore as the designated local GIR filing entity of the MNE group in place of the deemed designated local GIR filing entity.

(6) An application under subsection (5) must be made in the form and manner specified by the Comptroller.

(7) Where, after an entity (X) has been designated or deemed as the designated local GIR filing entity of the MNE group, any of the following events occurs or is expected to occur:(a)

X is wound up or otherwise dissolved;

(b)

X is struck off a register kept under the Companies Act 1967 or the Limited Liability Partnerships Act 2005;

(c)

X ceases to be registered under the Business Names Registration Act 2014 or the Limited Partnerships Act 2008 or has its registration thereunder cancelled;

(d)

X ceases to be a part of or to be connected to the MNE group, as the case may be;

(e)

any other event prescribed by the regulations,

then another constituent entity of the MNE group located in Singapore must be designated as the designated local GIR filing entity of the MNE group in place of X, not later than one month after the occurrence of the event or such extended time as the Comptroller may allow, and in accordance with subsection (2).

(8) Subsections (3) to (6) apply with the necessary modifications to a failure to comply with subsection (7) as they apply to a failure to comply with subsection (1).

(9) Where, at any time after an entity (X) has been designated or deemed as the designated local GIR filing entity of the MNE group, the MNE group has a new constituent entity located in Singapore, then another constituent entity of the MNE group located in Singapore may be designated as the designated local GIR filing entity of the MNE group in place of X in accordance with subsection (2) —(a)

within 6 months after the end of the financial year in which the acquisition of ownership or control occurred that resulted in the MNE group having the new constituent entity; or

(b)

such extended time as the Comptroller may allow.

(10) The constituent entity that replaced X as the designated local GIR filing entity of an MNE group under subsection (7) or (9) must carry out any duty under this Act of a designated local GIR filing entity that has yet to be carried out by X on the date specified under subsection (11).

(11) The designation or deeming of an entity as a designated local GIR filing entity under this section takes effect from the date specified by —(a)

the constituent entity that made the designation on behalf of all the represented entities of the MNE group; or

(b)

the Comptroller,

as the case may be.

(12) Where an entity has been designated as a designated local GIR filing entity of a registered MNE group under this section, the Comptroller must notify the ultimate parent entity of the MNE group (if located in Singapore), and all other represented entities of the MNE group, of the identity of the designated local GIR filing entity.