Singapore Issues Update on Pillar 2 Registration

On December 30, 2025, IRAS issued further details on the Pillar 2 registration process.

Section 31 of Singapore’s Minimum Tax 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 (UPE) of the MNE group must register within 6 months after the end of the group’s first financial year in which it is subject to the Minimum Tax in Singapore. 

If the UPE wishes to appoint a representative to register the MNE group on its behalf, the representative may be either a CE of the MNE group located in Singapore or a local tax agent.

The representative appointed by the UPE must submit the registration form together with a Letter of Authorisation. This letter, issued on the UPE’s company letterhead, must explicitly state that the appointed representative is authorised to submit the registration form and to act on behalf of both the UPE and the MNE group in all registration-related matters.

The IRAS update provides that the registration portal is to be open from May 2026, however, a draft registration form and explanatory notes have been issued (for information only until the submission process is finalised).

The guidance provides that the following information is requires

(1)Tax identification number (“TIN”) of all entities of the MNE group that are incorporated, registered or located in Singapore:

-CEs (including Permanent Establishments);
-Joint Ventures and Joint Venture subsidiaries;
-Minority-owned CEs;
-Investment entities or insurance investment entities;
-Reverse Hybrid Entities; and
-Excluded Entities

(2)If the MNE group has more than 30 in-scope entities and/or more than 30 excluded entities, separate excel/csv templates are provided to provide the details.

(3)For each entity of the MNE group, provide its TIN, jurisdiction of tax residency and the date of change in tax residency. This requirement applies only to entities incorporated or registered in Singapore that had shifted their tax residency from Singapore to a foreign jurisdiction after 30 November 2021.

(4)TIN and name of the CE located in Singapore to be appointed as both:

-the Designated Local GloBE Information Return (GIR) Filing Entity (GFE); and

-the Designated Local DTT Filing Entity (DFE).

(5)Name, designation and contact details of the contact person of the GFE and the DFE.

(6)Start and end dates of the MNE group’s first Financial Year to which the Minimum Tax Act applies.

See the Singapore GloBE Country Guide (below) for further information, including the domestic QDMTT design (including optional and mandatory variations), as well as our domestic Pillar 2 trackers.