Latest Updates

The e-Tax Guide has been updated with the following changes: 

• Amended paragraphs 4.1 and 4.2 to reflect that the Minister or the CIT may extend the deadline for the transferor to transfer its non-insurance business to a transferee, as well as extend the deadline for the dissolution or winding up of the transferor.
• Added “Special input tax recovery formula” as a GST issue in Annex B – Summary of GST Implications.

The e-Tax Guide has been updated with the following changes:

• Inserted a new paragraph 3.5 and new footnote 6 to state that Singapore’s MMT Act obtained transitional qualified status with effect from 1 January 2025.
• Inserted a new paragraph 5.3 on the determination of the annual revenue for the purpose of the revenue threshold.
• Updated the table at paragraph 7.3.8 on the top-up amount for a stateless entity that is a reverse hybrid entity formed, registered or incorporated in Singapore and is not a responsible member.
• Updated paragraph 7.3.10 to clarify the basis of translation for an MNE group whose FY ends in a month other than December.
• Inserted new footnotes 22 and 24 regarding securitisation entities.
• Updated the table at paragraph 9.1 regarding the allocation of tax with respect to hybrid entities and reverse hybrid entities.
• Updated paragraph 10.5 regarding an entity that is appointed as the DFE and GFE.
• Updated paragraphs 10.20 and 10.21 regarding extended record keeping requirements.
• Inserted a new paragraph 11.11 to clarify that FTC may be allowed where foreign DMTT paid by an entity of the MNE group on behalf of the group is recharged to the foreign entity based on an allocation consistent with Article 5.2.4 of the GloBE Model Rules.
• Inserted new FAQs at Annex A to clarify on MTT and DTT calculations and tax administration.
• Updated Annex B for changes from the Finance (Income Taxes) Act 2025.

The e-Tax Guide has been updated with the following changes: 

• Section 8 – Inserted a new section to clarify that QDMTT (or any substantially similar tax) and DTT should be taken into account when determining the tax paid in a foreign tax jurisdiction and in Singapore respectively, whereas qualified IIR and qualified UTPR (or substantially similar taxes) should not be taken into account.
  The new section also sets out that, for the purpose of determining the headline tax rate of the foreign tax jurisdiction, any QDMTT, qualified IIR and qualified UTPR (or substantially similar taxes) should not be taken into consideration.
  Consequently, the previous paragraphs 8 and 9, are renumbered to paragraphs 9 and 10 respectively, and the previous footnotes 15 and 16 are renumbered to footnotes 21 and 22 respectively.
• Annex 4 – Updated footnote 21 (previously footnote 15) to clarify the treatment in the new paragraph 8.2.

Added Senegal to the list of jurisdictions that have exchange relationships with Singapore.

Indicative margin for related party loans for 2026 has been added.

The e-Tax Guide has been updated with the following changes:

• To clarify the CIT’s approach to characterising a hybrid instrument as debt or equity for income tax purposes (i.e. paragraphs 5.2 and 5.3).
• To update on the tax treatment relating to hybrid instruments issued by an RBT (i.e. paragraph 8.5).
• Editorial changes to the e-Tax Guide.