Apportionment of expenses, allowances and donations in respect of income derived on or after 1 July 2021
8A.—(1) For the purpose of determining the income mentioned in regulation 5A(2), all of the following for which a deduction is allowable to an approved insurer under the Act, are to be apportioned in accordance with paragraph (2) between the general business in Singapore (excluding specified general business) of the insurer and the specified general business of the insurer:
(a)
any item of expenditure not directly attributable to the general business in Singapore (excluding specified general business) of the insurer;
(b)
capital allowances;
(c)
donations.
(2) For the purpose of paragraph (1), the portion of expenditure, capital allowances and donations to be apportioned to the general business in Singapore (excluding specified general business) of the approved insurer is that ascertained using the fraction where “Pig”, “Pigx”, “Pog” and “Pogx” have the same meanings given by regulation 5A(3).
(3) For the purpose of determining the income mentioned in regulation 5C(4), all of the following for which a deduction is allowable to an approved marine hull and liability insurer under the Act, are to be apportioned in accordance with paragraph (4) between the marine hull and liability insurance and reinsurance business in Singapore of the insurer and the other general businesses in Singapore of the insurer:
(a)
any item of expenditure not directly attributable to the marine hull and liability insurance and reinsurance business in Singapore of the insurer;
(b)
capital allowances;
(c)
donations.
(4) For the purpose of paragraph (3), the portion of expenditure, capital allowances and donations to be apportioned to the marine hull and liability insurance and reinsurance business in Singapore of the approved marine hull and liability insurer is that ascertained using the fraction where —
(a)
“Pig” and “Pog” have the same meanings given by regulation 5A(3), with each reference to approved insurer substituted with a reference to approved marine hull and liability insurer; and
(b)
“Pim” and “Pom” have the same meanings given by regulation 5C(5).
(5) For the purpose of determining the income mentioned in regulation 5E(4), all of the following for which a deduction is allowable to an approved specialised insurer under the Act, are to be apportioned in accordance with paragraph (6) between the specialised insurance business in Singapore of the insurer and the other general businesses in Singapore of the insurer:
(a)
any item of expenditure not directly attributable to the specialised insurance business in Singapore of the insurer;
(b)
capital allowances;
(c)
donations.
(6) For the purpose of paragraph (5), the portion of expenditure, capital allowances and donations to be apportioned to the specialised insurance business in Singapore of the approved specialised insurer is that ascertained using the fraction where —
(a)
“Pig” and “Pog” have the same meanings given by regulation 5A(3), with each reference to approved insurer substituted with a reference to approved specialised insurer; and
(b)
“Pis” and “Pos” have the same meanings given by regulation 5E(5).
(7) For the purpose of determining the income mentioned in regulation 7AA(2), all of the following for which a deduction is allowable to an approved captive insurer under the Act, are to be apportioned in accordance with paragraph (8) between the captive general business in Singapore (excluding specified captive business) of the insurer and the other general businesses in Singapore of the insurer:
(a)
any item of expenditure not directly attributable to the captive general business in Singapore (excluding specified captive business) of the insurer;
(b)
capital allowances;
(c)
donations.
(8) For the purpose of paragraph (7), the portion of expenditure, capital allowances and donations to be apportioned to the captive general business in Singapore (excluding specified captive business) of the approved captive insurer is that ascertained using the fraction where —
(a)
“Pig” and “Pog” have the same meanings given by regulation 5A(3), with each reference to approved insurer substituted with a reference to approved captive insurer; and
(b)
Picx” and “Pocx” have the same meanings given by regulation 7AA(3).
(9) The Comptroller may apply any alternative method of apportionment in place of any of the prescribed fractions in paragraph (2), (4), (6) or (8) if the Comptroller is satisfied that the alternative method is reasonable in the circumstances of the business of the insurer mentioned in that paragraph.