Singapore’s Inland Revenue Authority has updated its guidance on registration requirements for Multinational Enterprise Top-up Tax and Domestic Top-up Tax under the Multinational Enterprise (Minimum Tax) Act 2024, outlining new compliance obligations, filing deadlines, and transition-year rules for large multinational groups.
The Inland Revenue Authority of Singapore (IRAS) updated its guidance on 6 May 2026 on registration requirements for Multinational Enterprise Top-up Tax (MTT) and Domestic Top-up Tax (DTT) under the Multinational Enterprise (Minimum Tax) Act 2024 (MMT Act).
Under the updated guidance, all in-scope multinational enterprise (MNE) groups must complete a one-time registration for MTT, DTT, and the filing of the Global Anti-Base Erosion (GloBE) Information Return. The registration form must be submitted online within six months after the end of the group’s first financial year that falls within the scope of the MMT Act. Online registration submissions will become available from May 2026.
The guidance relates to Singapore’s implementation of Pillar Two top-up taxes under the OECD’s Base Erosion and Profit Shifting (BEPS) 2.0 framework. The rules apply to MNE groups with annual revenues exceeding EUR 750 million and are intended to ensure a minimum effective tax rate of 15%.
IRAS also clarified that MNE groups with financial years shorter than 12 months that begin and end in 2025 may request an extension where they cannot meet the standard six-month registration deadline. Applications must be submitted to IRAS by email with the subject line “Request for extension for registration under the MMT Act”, with approvals to be considered on a case-by-case basis.
Once registered, MNE groups will receive a Group Identification Number (Group ID). For DTT and GloBE Information Return purposes, the Corppass Administrator of the Designated Local DTT Filing Entity or GIR Filing Entity will automatically become the administrator for the Group ID. This administrator will be responsible for authorising users to manage tax matters through the myTax Portal from January 2027.
The updated guidance further clarifies the definition of a “transition year” for filing purposes. IRAS stated that the transition year will be determined on a worldwide basis across all jurisdictions in which the MNE group operates. Where a group falls within the scope of a qualified Income Inclusion Rule or Undertaxed Profits Rule in any jurisdiction during financial year 2024, FY2024 will be treated as the transition year, even if no IIR tax is ultimately payable in that jurisdiction.
IRAS also confirmed that updates to Constituent Entities, including incorporations and liquidations occurring after registration, will be permitted through the myTax Portal from January 2027.
Earlier, Singapore signed the Multilateral Competent Authority Agreement on the Exchange of GloBE Information (GIR MCAA) under Pillar Two of the OECD/G20 Inclusive Framework’s Two-Pillar Solution on 14 April 2026.
