A flow-through ultimate parent
A flow-through ultimate parent can produce a low entity-level ETR although its owners are already taxed. The module describes reductions for qualifying owners, including conditions involving taxation within 12 months after the financial year and a nominal or combined expected rate of at least 15%. Other defined categories include certain small resident natural-person holdings and specified resident government, nonprofit and pension owners. The relevant-owner conditions and income allocation must be demonstrated; flow-through status alone does not remove all income from GloBE.
Investment and insurance investment entities
Investment entities and insurance investment entities use separate calculations and specified elections, including tax-transparency or distribution-based treatment where eligible. Singapore DTT treatment can set their own top-up amount to nil, but income allocated to a Singapore owner may still affect that owner’s computation. Do not extend the entity-specific treatment to every investment structure or owner. Record the entity classification, owner conditions, allocated amounts and election history together when applying the neutrality provisions.
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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