Branches and flow-through entities
Where flow-through income is removed or allocated, its qualifying tax expense is reduced in the same proportion. Permanent-establishment and main-entity tax allocations follow the prescribed branch rules, including consequences of branch losses previously assigned to the main entity. The June 2026 module separates these allocations from ordinary withholding or cash-payment location. Track which entity’s income the tax relates to and where the corresponding GloBE amount is included.
DTT modifications and caps
Reallocation can cover CFC taxes, distribution taxes, hybrid and reverse-hybrid entities and joint ventures, subject to defined caps. The blended-CFC illustration has specified financial-year boundaries. For Singapore DTT, foreign main-entity taxes on a Singapore PE and foreign CFC taxes on a Singapore entity are not allocated in the same manner as the general GloBE calculation. Keep the MTT and DTT tax schedules separate and document both the allocation rule and its domestic modification to prevent overstating Singapore’s covered-tax numerator.
Official source
A concise, independent Apex Gateway guide based on the official English source, not a reproduction of the complete document. Consult the original for full conditions, exceptions and subsequent updates.
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