Ministry of Finance has issued new regulations on MNE minimum tax, detailing local filing entity designation, prescribed event notifications, record-keeping, and electronic service requirements, effective 31 December 2025 for financial years starting 1 January 2025.
The Singapore Ministry of Finance (MOF) has published the Multinational Enterprise (Minimum Tax) (Administrative Matters) Regulations 2025 (S 861) on 30 December 2025, providing detailed rules for the designation of local filing entities, record retention, and other administrative matters under the Multinational Enterprise (Minimum Tax) Act 2024.
The regulations take effect from 31 December 2025 and apply to the financial years of multinational enterprise (MNE) groups beginning on or after 1 January 2025.
Designation of local filing entities
Under the regulations, a constituent entity of a registered MNE group may be designated as the local GIR (Global Intangible Low-Taxed Income) or DTT (Domestic Top-Up Tax) filing entity. Key conditions include:
- The designate must preferably be the ultimate parent entity of the MNE group located in Singapore and not an excluded entity.
- If the ultimate parent entity is ineligible, an intermediate parent entity or a constituent entity, including a permanent establishment registered in Singapore, may be designated.
- Both the designated local GIR filing entity and DTT filing entity must be the same constituent entity.
Special provisions apply to multi-parent groups, limiting the designation to an entity treated as part of a single MNE group under existing regulations.
Notification of prescribed events
The regulations define “prescribed events” requiring notification to the Comptroller, including:
- Changes to information under section 31(2) as notified by the ultimate parent entity.
- Changes in the accounting period of the ultimate parent entity’s consolidated financial statements.
- Specific events affecting constituent entities under regulation 93 of the MNE Minimum Tax Regulations 2024.
Notifications must generally be submitted within six months after the end of the relevant financial year. The Comptroller may grant extensions in cases of reasonable cause.
Record-keeping requirements
Prescribed entities of MNE groups must retain records in safe custody as follows:
- Records relating to MTT payable by a chargeable entity must be kept for up to ten years if used for computing or evidencing information under specific regulations, or five years for other matters.
- Records relating to DTT must also be retained for up to ten years for computing or evidencing purposes, or five years for other matters.
Responsible members, constituent entities in Singapore, joint ventures, and section 29(b) entities are included in the scope of prescribed entities.
Prescribed interest rate and electronic service
The regulations set the prescribed interest rate at 1.5% points above the 3-month compounded SORA (Singapore Overnight Rate Average) for purposes of section 60(6).
The Comptroller may serve documents electronically, subject to consent and opt-out provisions. Notices of intention, refusal, or consent must be administered according to the rules, with an opt-out period of at least 14 days.
Earlier, the Inland Revenue Authority of Singapore (IRAS) issued the Multinational Enterprise (Minimum Tax) (Administrative Matters) Regulations 2025 on 29 December 2025, providing new guidance on registration for the multinational enterprise top-up tax and domestic top-up tax.
