Allocating top-up tax
Where the jurisdiction’s total GloBE result is positive, the ordinary allocation follows each positive-income entity’s share of total positive income; a loss entity receives zero under that formula. Negative-total-income cases and prior-year additional top-up amounts use different prescribed allocations. Singapore DTT can be paid through the designated entity or, under a section 45 election, by specified entities for their attributed amount. The illustrated payment allocation does not reduce the group’s total liability.
Testing the de minimis election
The annual election requires average adjusted revenue below EUR10 million and average GloBE income or loss below EUR1 million across the current and preceding two financial years, with rules for years lacking relevant amounts. Specified entities, such as stateless and investment entities, do not use the ordinary exclusion. It is not a EUR1 million threshold for each company separately or an automatic permanent exemption. Keep the grouping, three-year figures and GIR election together and distinguish this full-rule exclusion from transitional safe-harbour tests.
Official source
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