The Inland Revenue Authority of Singapore (IRAS) has released a new e-Tax Guide on the Multinational Enterprise (MNE) Top-up Tax (MTT) and Domestic Top-up Tax (DTT) on 31 December 2024.
This e-Tax guide sets out the key parameters of the MTT and DTT which are provided in the MMT Act and subsidiary legislations. Further guidance on MTT and DTT, such as on the transition rules and safe harbours, will be released progressively.
As announced in the 2024 Budget Statement, Singapore will implement a DTT and the IIR under Pillar Two of the BEPS 2.0 initiative, which will impose a minimum ETR of 15% on businesses’ profits from FYs starting on or after 1 January 2025. The MMT Act has been enacted to implement the IIR (which is referred to as the MTT in the Act) and DTT. The MTT and DTT are based on the published GloBE Model Rules, Commentary and AGs.
MTT and DTT apply to MNE groups with annual revenue of EUR 750 million or more in the CFS of the UPE in at least two out of the four preceding FYs (also known as in-scope MNE groups).
All registered MNE groups liable for MTT and / or DTT are required to file tax returns on their top-up tax liability in Singapore. All registered MNE groups are also required to file a GIR with Singapore, unless the GIR is filed with another jurisdiction and in such a case, a GloBE notification (if Singapore will receive the GIR through a filing made in another jurisdiction via exchange of information) must be filed with Singapore.
