§ 84 — Regulations

84.—(1) The Minister may make regulations —(a)

to provide for adjustments, including any allocation to or from another entity, to be made to the FANIL or the GloBE income or loss of entities (including adjustments to be made to the revenue of entities);

(b)

to provide for adjustments, including any allocation to or from another entity, to be made to the qualifying current tax expense, the qualifying deferred tax expense or the adjusted covered taxes of entities;

(c)

to provide for elections that may be made under the GloBE rules;

(d)

to provide for the modification of any provision of this Act where the ultimate parent entity of an MNE group is a flow‑through entity;

(e)

to provide for the allocation of the FANIL, the GloBE income or loss, the qualifying current tax expense or the qualifying deferred tax expense of a flow‑through entity in specified circumstances;

(f)

to provide for adjustments to be made to any negative tax carried forward, recaptured deferred tax liability or any other prescribed item for the purposes of any provision of this Act in a case where, after an MNE group first becomes liable to be registered under Part 4, it comes within the scope of the law of any jurisdiction imposing a qualified IIR or a qualified UTPR;

(g)

to provide for the currency in which calculations under this Act are to be carried out in specified circumstances, and the exchange rate applicable for MTT or DTT purposes;

(h)

to modify the provisions of the ITA (including any case law or principle of law interpreting those provisions) in their application in relation to MTT and DTT;

(i)

to provide for the modification of the application of any provision of this Act when an MNE group changes its financial year;

(j)

to provide for a procedure for an entity to submit requests to the Comptroller to resolve issues arising from differences in tax outcomes between Singapore and another jurisdiction in their respective laws because of different interpretations of the GloBE rules, the procedure for resolving these issues, and the provision of relief arising from such resolution;

(k)

to prescribe the agreements that are qualifying competent authority agreements;

(l)

to provide for the GloBE Safe Harbours, and matters relating thereto;

(m)

to create offences for a contravention of a provision of the regulations, the penalty for which on conviction may be a fine not exceeding $5,000 or to imprisonment for a term not exceeding 6 months or to both, and to provide for the composition of any such offence;

(n)

to provide for such saving, transitional and other consequential, incidental and supplemental provisions as are necessary or expedient for regulations made under this section;

(o)

to prescribe matters required or permitted by this Act to be prescribed; and

(p)

for the purposes of carrying out or giving effect to the provisions of this Act.

(2) Regulations made under this section may incorporate by reference (with or without modification) any part of the GloBE rules.

—(1) The Minister may make regulations —(a)

to provide for adjustments, including any allocation to or from another entity, to be made to the FANIL or the GloBE income or loss of entities (including adjustments to be made to the revenue of entities);

(b)

to provide for adjustments, including any allocation to or from another entity, to be made to the qualifying current tax expense, the qualifying deferred tax expense or the adjusted covered taxes of entities;

(c)

to provide for elections that may be made under the GloBE rules;

(d)

to provide for the modification of any provision of this Act where the ultimate parent entity of an MNE group is a flow‑through entity;

(e)

to provide for the allocation of the FANIL, the GloBE income or loss, the qualifying current tax expense or the qualifying deferred tax expense of a flow‑through entity in specified circumstances;

(f)

to provide for adjustments to be made to any negative tax carried forward, recaptured deferred tax liability or any other prescribed item for the purposes of any provision of this Act in a case where, after an MNE group first becomes liable to be registered under Part 4, it comes within the scope of the law of any jurisdiction imposing a qualified IIR or a qualified UTPR;

(g)

to provide for the currency in which calculations under this Act are to be carried out in specified circumstances, and the exchange rate applicable for MTT or DTT purposes;

(h)

to modify the provisions of the ITA (including any case law or principle of law interpreting those provisions) in their application in relation to MTT and DTT;

(i)

to provide for the modification of the application of any provision of this Act when an MNE group changes its financial year;

(j)

to provide for a procedure for an entity to submit requests to the Comptroller to resolve issues arising from differences in tax outcomes between Singapore and another jurisdiction in their respective laws because of different interpretations of the GloBE rules, the procedure for resolving these issues, and the provision of relief arising from such resolution;

(k)

to prescribe the agreements that are qualifying competent authority agreements;

(l)

to provide for the GloBE Safe Harbours, and matters relating thereto;

(m)

to create offences for a contravention of a provision of the regulations, the penalty for which on conviction may be a fine not exceeding $5,000 or to imprisonment for a term not exceeding 6 months or to both, and to provide for the composition of any such offence;

(n)

to provide for such saving, transitional and other consequential, incidental and supplemental provisions as are necessary or expedient for regulations made under this section;

(o)

to prescribe matters required or permitted by this Act to be prescribed; and

(p)

for the purposes of carrying out or giving effect to the provisions of this Act.

(2) Regulations made under this section may incorporate by reference (with or without modification) any part of the GloBE rules.