“authorised person” means a person authorised by the Comptroller under section 105L of the Act;
“constituent entity” —
(a)
in relation to an MNE group that is a Type A group, means any entity of the MNE group, whether or not the entity has a permanent establishment; and
(b)
in relation to an MNE group that is a Type B group, means the single entity of the Type B group, and includes a permanent establishment of the Type B group for which separate financial statements are prepared;
“country‑by‑country report” has the same meaning as in section 105I of the Act;
“entity” means any person that is not an individual, but excludes the Government, and the government of any country;
“FRS 110” means the financial reporting standard known as Financial Reporting Standard 110 (Consolidated Financial Statements) issued by the Accounting Standards Council under the Accounting Standards Act (Cap. 2B);
“MNE group” means a Multinational Enterprise group;
“Type A group” means a group of entities related through ownership or control in such a way that the group is either —
(a)
required to prepare consolidated financial statements for financial reporting purposes under FRS 110 or an equivalent financial reporting standard in a country outside Singapore; or
(b)
would have been so required if equity interests in any of the entities were traded on any stock exchange in Singapore or elsewhere;
“Type B group” means a single entity with one or more permanent establishments;
“ultimate parent entity” —
(a)
in relation to an MNE group that is a Type A group, means a constituent entity of the MNE group —
(i)
that owns, directly or indirectly, a sufficient interest in one or more constituent entities of the MNE group such that —
(A)
it is required under FRS 110 or an equivalent financial reporting standard in a country outside Singapore to prepare consolidated financial statements for the MNE group; or
(B)
it would have been so required if its equity interests were traded on any stock exchange in its jurisdiction of tax residence; and
(ii)
in which no other constituent entity of the MNE group owns (directly or indirectly) an interest described in sub‑paragraph (i); or
(b)
in relation to an MNE group that is a Type B group, means the single entity of the Type B group.
(2) In these Regulations, a Type A group is an MNE group for an accounting period if the Type A group —
(a)
has a consolidated group revenue of not less than $1,125 million (or its equivalent in foreign currency) in the accounting period immediately before that accounting period; and
(b)
has 2 or more entities that are resident for a tax purpose in different countries.
(3) In these Regulations, a Type B group is an MNE group for an accounting period if the Type B group —
(a)
has a revenue of not less than $1,125 million (or its equivalent in foreign currency) in the accounting period immediately before that accounting period; and
(b)
is resident for a tax purpose in one country and is also subject to income tax or tax of a similar character with respect to its business carried out through a permanent establishment in another country.