Singapore’s parliament passed two bills on 15 October 2024 – Multinational Enterprise (Minimum Tax) (Bill No.33/2024) and Income Tax (Amendment) Bill (Bill No. 32/2024.) – which introduces a top-up tax (MTT) and a domestic top-up tax (DTT) for large multinational corporations.
The MTT enables a multinational’s home country to impose additional tax if a related entity is taxed below 15% in another jurisdiction. The DTT is a domestic version of this tax, ensuring that companies paying less than 15% are brought up to the minimum threshold.
Earlier, the Inland Revenue Authority of Singapore initiated a Consultation on the Proposed Multinational Enterprise (Minimum Tax) Regulations – GloBE Safe Harbours and Transition Rules on 4 October 2024.
This initiative aligns with the OECD/G20 Inclusive Framework’s Global Anti-Base Erosion (GloBE) Rules under Pillar Two, which mandate that multinational enterprise (MNE) groups be taxed at a minimum effective rate of 15% to combat base erosion and profit shifting (BEPS).
