KNOWLEDGE|
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Multinational Enterprise Top‑up Tax (MTT): The Multinational Enterprise Top‑up Tax (MTT) is Singapore’s implementation of the Income Inclusion Rule (IIR) under the Global Anti‑Base Erosion (GloBE) rules. It applies when overseas subsidiaries of a Singapore‑headquartered MNE group are taxed below the 15% minimum effective tax rate. In such cases, a top‑up tax may be imposed on the parent entity in Singapore. |
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Domestic Top-up Tax (DTT): The Domestic Top‑up Tax (DTT) applies when Singapore constituent entities of an MNE group have an effective tax rate below 15%. The DTT allows Singapore to collect the additional tax required to bring the effective tax rate in Singapore up to the 15% minimum threshold. |
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Registration: MNE groups that are subject to the Multinational Enterprise Top‑up Tax (MTT) or Domestic Top‑up Tax (DTT) are required to register with IRAS via myTax Portal. Based on IRAS guidance, the registration process is expected to commence from 1 May 2026.
In‑scope groups must submit their registration within 6 months after the end of the first financial year in which the Pillar Two rules apply to the group.
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Filing Requirements: In‑scope MNE groups must submit the Global Anti‑Base Erosion (GloBE) Information Return (GIR) and the relevant Top‑up Tax Return to IRAS. Generally, the filing deadline is within 15 months (i.e by 31 March 2027)after the end of the relevant financial year(i.e 31 December 2025). However, for the first year of implementation, IRAS allows an extended timeline of up to 18 months(i.e 30 June 2027) after the end of the financial year. |
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Disclaimer All information in this article is only for the purpose of information sharing, instead of professional suggestion. Kaizen will not assume any responsibility for loss or damage. |
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