Singapore has implemented the Global Anti-Base Erosion (“GloBE”) rules under Pillar Two of the OECD’s international tax framework. The new rules apply to financial years beginning on or after 1 January 2025 and are administered under the Multinational Enterprise (Minimum Tax) Act 2024 (“MMT Act”).
In-scope multinational enterprise (“MNE”) groups with entities in Singapore must determine whether they are required to register with the Inland Revenue Authority of Singapore (“IRAS”) for:
- Multinational Enterprise Top-up Tax (“MTT”); and
- Domestic Top-up Tax (“DTT”).
Registration is time-sensitive. The registration form must generally be submitted within six months after the end of the MNE group’s first financial year to which the MMT Act applies.
What Are MTT and DTT?
Singapore’s Pillar Two regime is designed to ensure that large MNE groups are subject to a minimum effective tax rate of 15% in each jurisdiction where they operate.
Multinational Enterprise Top-up Tax
MTT implements the Income Inclusion Rule in Singapore. Broadly, it may impose top-up tax on a Singapore parent entity in respect of low-taxed constituent entities located outside Singapore.
Domestic Top-up Tax
DTT may impose additional tax where the effective tax rate of an in-scope MNE group’s Singapore entities is below 15%.
Singapore has implemented MTT and DTT for financial years beginning on or after 1 January 2025. The Undertaxed Profits Rule has not yet been implemented in Singapore.
Which MNE Groups Must Register?
An MNE group is generally required to register under the MMT Act if both of the following conditions are met:
- The group has annual revenue of at least €750 million, as reported in the consolidated financial statements of its Ultimate Parent Entity (“UPE”), in at least two of the four financial years immediately preceding the relevant financial year; and
- The group has at least one of the following in Singapore:
- Constituent Entity, including a permanent establishment;
- Joint Venture;
- Reverse Hybrid Entity incorporated or registered in Singapore; or
- Other entity falling within the registration scope of the MMT Act.
The assessment must be performed at the MNE group level. A Singapore company cannot determine its registration obligation by looking only at its own revenue, profit or tax position.
Registration may still be required even where no top-up tax is ultimately payable, for example because the group qualifies for a safe harbour or its jurisdictional effective tax rate is at least 15%.
Who Is Responsible for Registration?
The UPE is responsible for notifying the Comptroller of Income Tax by submitting the MNE group’s information through the prescribed online registration form.
This applies even when the UPE is incorporated outside Singapore and does not have a Singapore tax identification number.
Alternatively, the UPE may appoint an individual representative to submit the registration on behalf of the group. The representative must be either:
- An individual from a constituent entity of the MNE group located in Singapore; or
- A local tax agent.
Where a representative is appointed, the registration form must be accompanied by a Letter of Authorisation issued on the UPE’s letterhead. The letter should expressly confirm that the representative’s organisation is authorised to submit the registration and act for both the UPE and the MNE group in registration-related matters.
Registration Deadline
The registration form must be submitted within six months after the end of the MNE group’s first financial year to which the MMT Act applies.
Examples:
| First in-scope financial year | Registration deadline |
|---|---|
| 1 January 2025 to 31 December 2025 | 30 June 2026 |
| 1 April 2025 to 31 March 2026 | 30 September 2026 |
| 1 July 2025 to 30 June 2026 | 31 December 2026 |
For an MNE group with a financial year of less than 12 months that begins and ends in 2025 and is unable to register within six months after its financial year-end, an extension may be requested from IRAS. Such requests are considered on a case-by-case basis.
Information Required for Registration
The MNE group should prepare the following information before submitting the registration form:
1. MNE Group Information
- Legal name of the UPE;
- UPE’s jurisdiction of incorporation and tax residence;
- Group financial year start and end dates;
- First financial year to which the MMT Act applies; and
- Details of the person submitting the registration.
2. Singapore Entity Information
The tax identification numbers and relevant details of all entities incorporated, registered or located in Singapore, including:
- Constituent Entities;
- Permanent establishments;
- Joint Ventures and Joint Venture subsidiaries;
- Minority-owned Constituent Entities;
- Investment Entities;
- Insurance Investment Entities;
- Reverse Hybrid Entities; and
- Excluded Entities.
Where the group has more than 30 in-scope entities or more than 30 excluded entities, the applicable IRAS spreadsheet templates should be completed and uploaded instead of entering every entity separately in the online form.
3. Changes in Tax Residence
For an entity incorporated or registered in Singapore that changed its tax residence from Singapore to another jurisdiction after 30 November 2021, the following information is required:
- Entity name and tax identification number;
- Current jurisdiction of tax residence; and
- Effective date of the change in tax residence.
4. Designated Singapore Filing Entity
The MNE group must identify a Singapore Constituent Entity to be appointed as both:
- The Designated Local GloBE Information Return Filing Entity (“GFE”); and
- The Designated Local DTT Filing Entity (“DFE”).
The registration requires the name and tax identification number of the appointed entity, together with the name, designation and contact details of the relevant contact person.
5. Letter of Authorisation
A Letter of Authorisation is required if the registration is submitted by an appointed representative instead of directly by the UPE.
What Happens After Registration?
IRAS generally aims to process a complete registration within one month. Processing may take longer if information is incomplete or clarification is required.
Once registration is approved:
- The MNE group will be assigned a Group Identification Number;
- IRAS will issue registration notifications to the relevant responsible members in Singapore; and
- The Group ID will subsequently be used for filing the DTT Return and GloBE Information Return through myTax Portal.
If an error is discovered after submitting the registration form, the group should not submit a second registration form. Instead, the acknowledgement number of the original submission should be quoted when contacting IRAS to request a correction.
Consequences of Failing to Register
An in-scope MNE group that fails to notify IRAS of its registration liability may be subject to a surcharge of 10% of the applicable DTT and MTT.
Groups should therefore complete their scope assessment early, confirm the relevant filing entities and obtain the necessary information from the UPE and overseas group entities before the registration deadline.
How Ascend Can Assist
Ascend Corporate Service Pte. Ltd. can assist MNE groups with their Singapore Pillar Two registration and compliance preparations, including:
- Reviewing whether the MNE group falls within the registration scope;
- Identifying Singapore in-scope and excluded entities;
- Preparing the registration information checklist;
- Reviewing entity classification and tax residence information;
- Coordinating with the UPE and overseas group advisers;
- Preparing the Letter of Authorisation;
- Assisting with the appointment of the designated Singapore filing entity;
- Submitting the registration as an authorised local tax agent; and
- Supporting subsequent DTT computation and filing preparations.
Early preparation is particularly important for MNE groups with multiple Singapore entities, changes in tax residence, complex ownership structures or significant differences between their consolidated financial statements and local statutory accounts.
For assistance with MTT and DTT registration in Singapore, please contact Ascend Corporate Service Pte. Ltd.
This article is intended for general information only and does not constitute tax or legal advice. The applicable treatment depends on the MNE group’s structure, financial information and particular circumstances.
Official references: IRAS – Registration for MTT and DTT and IRAS – GloBE Rules and DTT.
