Singapore’s 2026 Income Taxes Bill Includes Pillar Two Amendments

Singapore has opened a consultation on the proposed Finance (Income Taxes) Bill 2026, a package that would amend the Income Tax Act 1947 and the Multinational Enterprise (Minimum Tax) Act 2024 (MMTA).  The Bill contains 22 amendments: 20 amendments to the Income Tax Act and two amendments to the MMTA. The two MMTA changes are to implement the Side-by-Side Safe Harbour under the OECD’s January 2026 package and to implement the GloBE information return exchange framework.

Side-by-Side Safe Harbour

The proposed Bill would support Singapore’s implementation of the Side-by-Side Safe Harbour, part of the OECD’s January 2026 Side-by-Side package. MOF’s Annex C explains that the safe harbour effectively exempts the income of MNE groups headquartered in a jurisdiction with a qualified side-by-side regime from the application of the Income Inclusion Rule and Undertaxed Profits Rule in other jurisdictions. The proposed amendments are intended to allow Singapore’s Minister to make regulations implementing that safe harbour, with application to MNE groups for financial years beginning on or after 1 January 2026.

IRAS has also said Singapore will implement the Side-by-Side package in accordance with the Inclusive Framework agreement. Subject to Parliament’s approval, Singapore expects amendments to the MMTA and the Multinational Enterprise (Minimum Tax) Regulations 2024 by the end of 2026; IRAS states that the amendments will extend the Transitional CbCR Safe Harbour and adopt, for financial years commencing on or after 1 January 2026, the Substance-based Tax Incentive Safe Harbour and the Side-by-Side Safe Harbour. Singapore has not implemented the UTPR, so IRAS states that there is no need for Singapore to adopt the UPE Safe Harbour.

This will therefore be implemented via regulations and dynamic OECD references. Clause 36 would amend section 20 of the MMTA on GloBE safe harbours; the Explanatory Statement says this would allow the new Side-by-Side Safe Harbour to apply to stateless entities. Clause 41 would also allow safe harbour regulations to refer to a webpage on a prescribed OECD website ‘as amended from time to time,’ so that eligibility for a qualified side-by-side regime can track OECD determinations.

GloBE Information Returns