| Status | Enacted Law |
| Law | Finance (Income Taxes) Act 2026 (Act 23 of 2026), passed 6 October, assented 29 October and published 4 November 2026. The Act contains the Pillar Two GIR, return, appeal, secrecy, DTT accounting and Side-by-Side enabling amendments, with split commencement. Sections 36, 40–48 and 49(a) and (c) commenced on 4 November 2026. Sections 38 and 49(b) are deemed in force from 1 January 2026. Sections 37, 39, 49(d) and 50 await ministerial commencement, including the DTT currency, JV and financial-accounting basis changes. Read our enacted-law analysis. 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 was enacted on December 8, 2025. 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). This now needs to be assented to by the President. Multinational Enterprise (Minimum Tax) Bill, 2024 of September 9, 2024 Draft Multinational Enterprise (Minimum Tax) Regulations 2025 of June 10, 2024 On October 4, 2024, Singapore issued a Consultation document on the GloBE Safe Harbours and Transition rules |
| Effective Date | Financial years beginning on or after January 1, 2025 |
| IIR | Yes (2025) |
| UTPR | No |
| QDMTT | Yes (2025) |
| Filing Deadlines | GIR and MTT/DTT returns: 15 months after financial year-end, increased to 18 months for the transition year. From 4 November 2026, MMTA sections 40(4A)–(4B) allow the Comptroller to require the designated local GIR filing entity to file locally if an overseas-filed GIR is not received within the qualifying agreement period. The written notice sets the actual deadline and must allow at least one month. New sections 41(7) and 43(7) permit MTT/DTT return exemptions by Gazette order; the enabling powers alone do not exempt a group. GIR-MCAA signature and enactment do not establish an activated partner relationship. |
| Safe Harbours | Transitional CbCR Safe Harbour, QDMTT Safe Harbour and Simplified Calculations for NMCEs Safe Harbour. Sections 38 and 49(b) of the Finance (Income Taxes) Act 2026 enact the Side-by-Side enabling changes with effect from 1 January 2026. Detailed operation remains subject to the relevant regulations and OECD qualification material. The Act alone does not establish that all announced package measures are operative or that a group qualifies. DTT continues to apply where Side-by-Side MTT relief is available. |
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