Module scope and the June 2026 edition
Module Six contains forty-two slides on Glo BE safe harbours. The filing entity elects in the GIR for specified jurisdictional entities; qualifying top-up amounts are treated as nil. This simplifies calculations but does not automatically remove reporting or the domestic tax itself. The source distinguishes Transitional Cb CR, QDMTT and Simplified Calculations safe harbours. Transitional UTPR relief, with a UPE-jurisdiction corporate rate of at least twenty percent, is mentioned but not taught because Singapore has not implemented UTPR.
Transitional Cb CR: period and continuous election
TCSH applies to MTT and DTT for financial years starting on or before 31 December 2026 and ending on or before 30 June 2028. Election must begin with the first year that the jurisdictional entities enter qualified IIR/UTPR or MMT Act scope and continue for preceding relevant years. Example: failing to elect for 1 July 2025–30 June 2026 prevents later entry. These are the dates taught in this June 2026 edition, not a statement that later extensions cannot exist.
Eligible entities and special restrictions
Ordinary CEs, connected JVs and MOCEs can qualify where conditions are met. An IE/IIE qualifies only if all group CEs directly owning it are in the same jurisdiction and no tax-transparency or taxable-distribution-method election is made. Entities in a UPE flow-through entity’s jurisdiction fail unless that UPE-FTE has nil Glo BE income and no PE FANIL allocated to it. Stateless entities cannot qualify.
Five entry conditions and source data
Meet the financial-year dates, prepare a qualifying CbC report, preserve elections in all preceding relevant years, make no deemed-distribution-tax election for any jurisdictional CE in that year, and pass at least one of three tests. If no CbC filing is required, GIR must contain the information such a report would contain. A partial CbC report does not qualify.
Three TCSH tests and the strict boundaries
De minimis requires revenue including held-for-sale CEs below EUR 10 million and pretax profit below EUR 1 million. Simplified ETR requires adjusted income-tax expense divided by pretax profit at least sixteen percent for years starting in 2025 or seventeen percent for 2026. Routine profits requires pretax profit below SBIE, or nil pretax profit/net loss. The slide prints a strict below-SBIE test here, while its later simplified-calculations slide uses SBIE greater than or equal to income; keep these source formulations distinct.
Simplified income-tax expense adjustments
Remove noncovered taxes, uncertain-tax-position amounts and specified deferred-tax expense from reversals of attributes described in Regulations 91(1)(b)/91(2), such as pre-regime governmental arrangements or retrospective elections. Amounts includible under the specified Regulation 91(3) grace-period rule remain eligible. Do not substitute total accounting tax expense without these adjustments.
Separate tested jurisdictions within one country
Ordinary CEs including PEs, MOCEs and qualifying IEs/IIEs constitute one tested jurisdiction. Each standalone JV and each JV group are tested separately, even in the same country. Passing the ordinary-CE test does not automatically qualify its unrelated JV test population.
Qualified financial statements and PE accounts
Use financial accounts for UPE consolidation or reliable separate CE statements under acceptable/authorised standards. Accounts for CEs omitted solely for size/materiality can qualify. A PE lacking its own qualifying statements may use separate main-entity accounts prepared for reporting, regulatory, tax or internal-control purposes to allocate PE revenue/profit. PPA-adjusted accounts require the additional conditions rather than automatically qualifying.
PPA consistency and goodwill impairment
Reports for financial years starting after 31 December 2022 must consistently include PPA adjustments; a legally compelled switch from prior exclusion can still meet consistency. For transactions after 30 November 2021, add goodwill-impairment reductions back to pretax profit for routine-profit testing. Simplified ETR adds them back only if deferred-tax assets/liabilities were not adjusted for the impairment.
Consistency within a tested jurisdiction, flexibility across countries
Use one source type for all entities within a tested jurisdiction: UPE consolidation accounts or reliable acceptable/authorised separate CE statements. Permitted small-entity/PE exceptions remain. Mixing source types otherwise disqualifies that tested jurisdiction. Different countries can use different qualifying types; a report can qualify for some jurisdictions while others fail.
Unrealised fair-value losses and investment-owner allocation
Exclude net unrealised fair-value loss exceeding EUR 50 million from pretax profit, except where total ownership interest is below ten percent. Attribute an IE/IIE’s revenue, profit and tax only to group direct owners in ownership proportions. The diagram has Singapore CE owners at seventy and twenty percent and an outside third party at ten: ninety percent enters the Singapore test.
Hybrid arbitrage: three categories and the date trigger
Exclude relevant losses/expenses from pretax profit and related income-tax expenses from simplified tax expense for deduction/non-inclusion, duplicate-loss and duplicate-tax-recognition arrangements entered after 15 December 2022. Later amendments/transfers, changes in rights/obligations or accounting treatment can cause an older arrangement to fall after that date.
Deduction/non-inclusion and both qualifications
Investment by CE A producing another CE B’s loss/expense without commensurate A revenue/taxable income is targeted; additional-tier-one-capital-only losses are excepted. An income inclusion is not commensurate to the extent offset by specially valuation/recognition-adjusted tax attributes, or where the payment also creates a tax deduction/loss in B’s jurisdiction without a corresponding jurisdictional pretax expense, including specified flow-through accounts.
Duplicate losses and tax recognition exceptions
An expense/loss in another CE’s accounts or tax deductions is duplicate unless offset by revenue recognised in both accounts, or one account and the other’s taxable income. If both accounting CEs share a jurisdiction, adjust one only. Repeated tax expense across CEs’ adjusted covered taxes/simplified ETR is excluded unless the associated income is also recognised; an exception covers duplication arising solely because simplified ETR does not reallocate taxes to another CE as full Glo BE would.
QDMTT safe harbour: purpose and three conditions
This applies to MTT only, not DTT, avoiding an extra Glo BE calculation in addition to domestic QDMTT. The group must fall within that jurisdiction’s QDMTT law, the jurisdiction must have safe-harbour-qualified status, and no applicable disqualification must arise. Singapore DTT is designed to meet the requirements, but domestic DTT liability is not removed by this MTT safe harbour.
Status, entity categories and separate elections
Peer review determines status; self-certification is a temporary step pending full legislative review. MTT refers to OECD’s periodically updated Central Record. Absence from it does not prove legislation unqualified because review may be pending. Ordinary CEs, JVs/JV subsidiaries, IEs/IIEs and MOCEs can qualify, with separate elections for each entity category.
All six QDMTT disqualifications
A: non-UPE responsible flow-through member is not taxed. B: initial-international-activity exemption is not restricted to entities outside qualified IIR and applies to the group. C: the QDMTT is contested or not assessable/collectible. D: a securitisation entity is excluded or its amount cannot be collected. E: specified deferred-tax attributes are not excluded consistently with Article 9.1 guidance from covered-tax and TCSH calculations. F: entities are outside the QDMTT scope. The matrix applies A–E to all four categories, while F applies to JVs/JV subsidiaries and IEs/IIEs, not ordinary CEs or MOCEs.
Switch-off is category-specific
An applicable disqualification switches the affected entity category from safe harbour to the QDMTT credit method for that jurisdiction/year. The diagram’s Singapore UPE owns a CE and IE in X: the IE’s disqualification switches off its category, while the unaffected CE can retain nil MTT under the harbour.
Simplified-calculations eligibility and NMCE definition
This harbour applies to MTT and DTT for ordinary-CE, MOCE and IE/IIE subgroups, if at least one jurisdictional subgroup member is a nonmaterial CE and a relevant test passes. An NMCE is omitted from consolidation solely for size/materiality, its consolidation framework is acceptable or adjusted against material competitive distortions, the CFS are externally audited, and revenue over EUR 50 million requires its CbC accounts to use acceptable/authorised standards. A qualifying PE is NMCE only if its main entity is also NMCE.
Simplified-calculations tests and annualisation
Routine profits requires SBIE at least subgroup Glo BE income/loss. De minimis uses current plus two prior financial-year average adjusted revenue below EUR 10 million and income/loss below EUR 1 million; it does not apply to IE/IIE subgroups. ETR requires at least fifteen percent. Annualise non 365-day revenue/income figures by 365 divided by financial-year days. The nil result excludes additional-current-top-up amounts, which remain separate.
NMCE calculations and the election diagram
Elect in the year’s GIR separately for each NMCE. Its Glo BE income and adjusted revenue may use CbC-regulation total revenue, and its adjusted covered tax may use accrued current tax expense under those rules. In the final example, an ordinary CE and unelected NMCE 1 retain full Glo BE computations, while elected NMCE 2 uses CbC entity figures; aggregate the subgroup to test relief. This is not an instruction to replace all group entities’ calculations with total revenue.
Official source
This article independently explains the substantive contents of the official PDF, including the relevant conditions, procedures and annexes. The linked document remains the authoritative source for its original wording, and later changes should be checked separately.
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