Pillar 2 Dashboard: Singapore

On October 14, 2025, the Finance (Income Taxes) Bill 2025 was published. This includes a number of amendments to the Global Minimum Tax provisions for the June 2024 OECD Administrative Guidance.

On December 30, 2024, Singapore published the Multinational Enterprise (Minimum Tax) Regulations 2024 which provide for the detailed rules for the application of the multinational top-up tax (MTT) and domestic top-up tax (DTT).

On November 27, 2024, the Multinational Enterprise (Minimum Tax) Act 2024 was published in Singapore’s Official Gazette.

On October 15, 2024, Singapore’s Parliament passed the Multinational Enterprise (Minimum Tax) Bill which includes a multinational top-up tax (MTT) and a domestic top-up tax (DTT).

On October 4, 2024, Singapore issued a Consultation document on the GloBE Safe Harbours (Transitional Country-by-Country Reporting Safe Harbour, QDMTT Safe Harbour and the Simplified Calculations Safe Harbour).

On September 9, 2024, Singapore introduced its Multinational Enterprise (Minimum Tax) Bill, 2024 into Parliament. The Bill is based on the previously issued draft law, with a number of amendments.

On June 10, 2024, the Singapore Ministry of Finance issued a draft Multinational Enterprise (Minimum Tax) Bill and subsidiary legislation for consultation. The consultation is open until July 5, 2024.

GLOBE APPLICATION

General

The Law does not contain any provisions for the implementation of the UTPR. This is in line with the 2024 Budget, which stated that the UTPR is not yet being implemented.

The implementation of the OECD Model Rules and subsequent Administrative Guidance is split between the Law and the Regulations. The Law provides the fundamental structure of the GloBE rules in Singapore with the regulations providing the more detailed GloBE income and covered taxes adjustments in order to calculate the GloBE effective tax rate (ETR).

The Regulations also provide guidance on some other aspects including the GloBE reorganisation rules and the rules for multi-parented MNE groups (chapter 6 of the OECD Model Rules), as well as the Safe Harbours.

The Finance (Income Taxes) Bill 2025 provides that Regulations may provide that a tax is a qualified domestic minimum top‑up tax, qualified IIR or qualified UTPR and that the Regulations may do so by reference to a webpage that is accessible from a prescribed Internet website of the OECD.

Administrative Guidance

Aspects of the First Set of OECD Administrative Guidance included in the Law are:

-Rebasing monetary thresholds in the GloBE Rules (Article 1.1)

-Consolidated deferred tax amounts (Article 1.3)

-Sovereign wealth funds and the definition of Ultimate Parent Entity (Article 1.4)

-Meaning of “ancillary” for non-profit organisations (Article 1.6)

-Excess negative tax carry-forward guidance (Article 2.7)

-The exclusion of insurance investment entities from the definition of intermediate parent entity and partially-owned parent entity (Article 3.2)

Aspects of the First Set of OECD Administrative Guidance included in the Regulations are:

-The foreign exchange hedge election (Article 2.2)

-The debt release election (Article 2.4)

-Provisions for accrued pension expenses (Article 2.5)

-Substitute loss carry forwards (Article 2.8)

-The equity gain or loss inclusion election (Article 2.9)

-Rules for blended CFC tax regimes (Article 2.10)

-Application of Taxable Distribution Method Election to Insurance Investment Entities (Article 3.1)

-Provisions on restricted tier one capital for insurance companies (Article 3.3)

-Liabilities related to excluded dividends and excluded equity gain or loss from securities held on behalf of policyholders (Article 3.4)

-The portfolio shareholding election (Article 3.5)

-Deferred tax transition rules (Articles 4.1-4.3)

Aspects of the Second Set of OECD Administrative Guidance included are:

-Currency conversion rules (Article 1)

-Marketable transferable tax credits (Article 2)

-Substance-based income exclusion rules (foreign assets, leases and impairment loss-es) (Article 3)

-QDMTT Safe Harbour

The only aspects of the Third set of OECD Administrative Guidance (issued in December 2023) included (aside from Safe Harbour rules) are:

-Identifying Consolidated Revenue (Article 3.1)

-Mismatch between Fiscal Years of the UPE and another Constituent Entity (Article 3.1)

On October 14, 2025, the Finance (Income Taxes) Bill 2025 was published. This includes a number of amendments to the Global Minimum Tax provisions for the June 2024 OECD Administrative Guidance. This includes, in particular:

-Determining GloBE status when a Flow-through Entity is held directly by another Flow-through Entity (Article 5.2.2)

-Non-group owners: Partially owned Flow-through Entities (Article 5.3.2)

-Non-group owners: Indirect minority ownership (Article 5.3.5)

-Taxes allocated to a flow-through entity (Article 5.4.2)

-Hybrid entities – Taxes pushed down include indirect owners (Article 5.5.2)

-New definition: Securitization Entity (Article 6.1.4)

-New definition: Securitization Arrangement (Article 6.1.4)

Safe Harbour and Penalty Relief Guidance

Section 20 of the Law provides for the application GloBE Safe Harbours. However, the detailed provisions are included in the Regulations.

Part 9, Division 2 of the Regulations provides for the Transitional Country-by-Country Reporting (“CbCR”) Safe Harbour based on the OECD Safe Harbour and Penalty Relief Guidance. The following amendments included in the December 2023 OECD Administrative Guidance are included:

-Transitional CbCR – Purchase Accounting Adjustments (consistent reporting condition, goodwill impairment adjustment) (Article 1)

-Transitional CbCR – JVs (Article 2.2.1)

-Transitional CbCR – MNEs not required to file CbC Reports (Article 2.3.4)

-Transitional CbCR – Qualified Financial Statements for PEs (Article 2.3.5)

-Transitional CbCR – Treatment of hybrid arbitrage arrangements (Article 2.6)

Sections 78-83 apply the QDMTT Safe Harbour which applies to QDMTTs that have been identified in a Regulation as meeting the QDMTT requirements.

It specifically applies the Switch-off rule to a number of defined scenarios as provided in the OECD Administrative Guidance. This includes where a jurisdiction imposing a QDMTT provides that it does not apply to an MNE group in the initial phase of the MNE group’s international activity (with no limitations).

Section 84-86 of the Regulations includes the Simplified Calculations Safe Harbour for Non-Material Constituent Entities as based on the OECD Safe Harbour Guidance (and the December 2023 OECD Administrative Guidance).

ELECTIONS

Elections in the OECD Model Rules

The Law and Regulations include all of the key elections as provided in the OECD Model Rules, including:

-Excluded Entity Election (First schedule, (5) of the Law)

-Election to use the Realization Method (S30 of the regulations)

-Stock-Based Compensation Election (31 of the regulations)

-Election to Spread Capital Gains (S32 of the regulations)

-Consolidation Election (S33 of the regulations)

-GloBE Loss Election (S47 of the regulations)

-Unclaimed Accrual Election (45(5) of the regulations)

-Distribution Tax Regime Election (S48 of the regulations)

-Substance-Based Income Exclusion Election (S18(9) of the Law)

-Prior Year Adjustment Election (S40(3) of the regulations)

-De minimis Election (S19 of the Law)

-Taxable distribution Election (S64 of the regulations)

-Tax transparency Election (S63 of the regulations)

Elections in the Administrative Guidance

All other elections included in the OECD Administrative Guidance are specifically included in the Law and Regulations. This includes the:

-Debt Release Election (S29 of the regulations);

-Foreign Exchange Hedge Election (S35 of the regulations);

-Portfolio Shareholding Election (S13(3) of the regulations);

-Excess Negative Tax Carry-Forward Election (S17(4)/21/24(10) of the Law);

-Equity Investment Inclusion Election (S34 of the regulations).

DEVIATIONS FROM THE OECD MODEL RULES/EU GLOBAL MINIMUM TAX DIRECTIVE

The main differences relate to the design of the QDMTT and the implementation of the OECD Administrative Guidance.

DOMESTIC MINIMUM TAX

General

Part 3 of the law provides for a qualified domestic minimum top‑up tax (‘QDMTT’) (or at least a domestic minimum tax that is likely to be classed as a QDMTT) for fiscal years beginning on or after January 1, 2025.

QDMTT Design Features

Section 27 of the Law states that the intention is for the domestic minimum tax to be a QDMTT within the meaning of the GloBE Rules. Section 27(4) provides that the Law is to be interpreted in a manner that is consistent with this.

The amount of top-up tax under the QDMTT is the top-up tax calculated under the general rules. The Law/regulations provide for a number of adjustments:

Firstly, Section 30 of the Law ensures that the QDMTT applies irrespective of the shareholdings in the group entities located in Singapore. This reflects the OECD Administrative Guidance that provides that Top-up Tax that is subject to the QDMTT is based on the whole amount of the jurisdictional Top-up Tax calculated, irrespective of the ownership interests held in the Constituent Entities located in the QDMTT jurisdiction by any Parent Entity of the MNE Group.

Secondly, it applies the QDMTT to stateless entities.

Under the OECD Administrative Guidance, a domestic minimum tax does not need to apply to Stateless Constituent Entities to be a QDMTT. However, jurisdictions can impose a QDMTT on these entities when they are created under the domestic Law of the jurisdiction.

Tax paid or incurred by a Constituent Entity-owner under a CFC Tax Regime that is pushed down to a domestic Constituent Entity in the GloBE Rules must be excluded, as provided in the OECD Administrative Guidance. This is included in Section 49 of the regulations.

Section 49 of the regulations also prevents the pushdown of tax to hybrids, PEs and for taxes on distributions (aside from Singaporean withholding tax on distributions).

Section 6 of the First Schedule to the Law provides that instead of using the UPEs accounting standard, MNEs can calculate GloBE income using domestic Accounting Standards (within the meaning of the Singapore Accounting Standards Act 2007).

For this to apply all the constituent entities of the MNE located in Singapore must prepare financial statements based on those Accounting Standards and their financial year must be the same as the consolidated financial statements.

The financial statements must also be subject a statutory audit or be required under a Singapore Law to be kept or used.

If these conditions are not met, the domestic minimum tax is calculated:

– using the financial accounting standard of the ultimate parent entity, and, if that is not practicable,

– on the basis of an accepted or approved accounting standard, if:

         -the constituent entity’s financial statements are prepared in accordance with that standard,

          -the information contained in the financial statements is reliable; and

           -permanent differences of more than EUR 1 million are conformed with the UPEs accounting standard.

The Second set of OECD Administrative Guidance also provides that where all the constituent entities use the domestic accounting standard and use the Singapore dollar as their functional currency in preparing those financial statements, the calculations for the purposes of the QDMTT are to be carried out in the Singapore dollar.

Where not all Constituent Entities in the jurisdiction use the Singapore dollar as their functional currency, Section 9(5) of the Law provides that the Filing Constituent Entity may make a Five-Year Election to undertake the QDMTT computations for all Constituent Entities in the jurisdiction either:

• in the presentation currency of the Consolidated Financial Statements; or

• in the Singapore dollar.

As required in the OECD Administrative Guidance, Section 30(8) of the Law also requires that any GloBE election made (or revoked) is taken into account for QDMTT purposes, if the election is included in a GloBE Information Return that would affect the top-up tax calculation.

Section 30(10) excludes investment entities and insurance investment entities from the scope of the QDMTT.

Transitional Year

Section 93 of the Regulations provides for the transitional year refreshing rule.

A new transition year, arises in an accounting period in which the entities of an MNE/domestic fall within the scope of a qualified IIR or UTPR if this accounting period begins after the beginning of the transition year for QDMTT purposes.

In the new transition year the following attributes of the relevant Constituent Entities are refreshed:

-Any Excess Negative Tax Expense Carry-forward under Article 4.1.5 or Article 5.2.1 is eliminated at the beginning of the new Transition Year.

-The DTL recapture rule in Article 4.4.4 does not apply to any deferred tax liability that was taken into account in computing the ETR under the QDMTT and that was not recaptured prior to the new Transition Year.

-Any GloBE Loss Deferred Tax Asset that arose in a year preceding the new Transition Year must be eliminated. The Filing Constituent Entity may make a new GloBE Loss election in the new Transition Year.

-The deferred tax items previously determined are eliminated and Article 9.1.1 is applied at the beginning of the new Transition Year.

-Article 9.1.2 applies to transactions occurring after November 30, 2021 and before the beginning of the new Transition Year. However, if QDMTT was payable due to the application of Article 4.1.5 in respect of a deferred tax asset attributable to a tax loss, the deferred tax asset is not treated as arising from items excluded from the computation of GloBE Income or Loss under Chapter 3 of the OECD Model Rules.

Registration

Section 31 of the Law provides that an MNE group subject to the GloBE rules in Singapore is required to register with the Singaporean tax authority.

The ultimate parent entity of the MNE group must, within 6 months after the end of the financial year, notify the tax authority of the following:

(a) the liability of the MNE group to be registered;

(b) the identities of the MNE group’s constituent entities, joint ventures, and JV subsidiaries, located in Singapore;

(c) the identities of the MNE group’s excluded entities located in Singapore;

(d) the identities of any flow-through entities or reverse hybrid established, formed, incorporated or registered under the laws of Singapore;

(e) the identities of the MNE group’s ultimate parent entity, intermediate parent entities, and partially-owned parent entities located in Singapore;

(f) the identities of the MNE group’s responsible members located in Singapore; and

(g) whether the GloBE information return has been or is intended to be filed with a competent authority of a jurisdiction outside Singapore pursuant to a qualifying competent authority agreement.

Filing

The relevant aspects of the submission of a GloBE Information Return (GIR) are included, as provided in the OECD Guidance

The proposed approach is that every Constituent Entity located in Singapore will have an obligation to file a GIR in Singapore. However, this obligation can be discharged if the GIR is filed by:

-The Ultimate Parent Entity, or

-The Designated Filing Entity.

Where the GIR is being filed by either the Ultimate Parent Entity or the Designated Filing Entity, the Constituent Entity, must file a notification with the Revenue.

The notification must contain:

-Details of the entity that is filing the GIR, and

-The jurisdiction in which such an entity is located.

Where the GIR is filed by the Designated Local Entity it needs to outline the Constituent Entities that it is filing on behalf of.

Both the GIR and associated notifications must be filed no later than 15 months after the end of the fiscal year (with an 18-month deadline for the Transition Year).

Section 41 of the Law also requires submission of a multinational top-up tax return (referred to as an ‘MTT Return’) where top-up tax is payable.  The same filing deadline applies for the MTT Return as for the GloBE Information Return. Section 43 of the Law applies the same rules to the domestic top-up tax return (DTT Return).

Payment

Sections 42 and 44 of the Law provide that any MTT or DTT must be paid within 1 month of the MTT/DTT return filing deadline.

The payment must be made in Singapore dollars.

Section 45 of the Law provides that an MNE group may, through its designated local DTT filing entity, elect for the part of its top-up amount for a financial year that is attributable to a constituent entity of the MNE group, to be paid separately.

Unless the Singapore tax authority permits otherwise, an MNE group must not make this election in respect of more than 30 entities for any financial year.

Penalties

Surcharge for failure to register

Section 50 of the Law applies a Surcharge for failure to register where the ultimate parent entity of an MNE group to fails to register the MNE group in accordance with domestic law.

Failure to file GloBE information return

Section 64 of the Law provides that any person who fails or neglects without reasonable excuse to file a GloBE Information Return is guilty of an offence and shall be liable on conviction to:

-a fine not exceeding $5,000 and in default of payment to imprisonment for a term not exceeding 6 months; and

-in the case of a continuing offence, to a further fine of $100 for every day during which the offence is continued after such conviction.

None issued.