Registration for Multinational Enterprise Top-up Tax and Domestic Top-up Tax

Following the announcement in the 2024 Budget Statement, Singapore has implemented the following taxes effective for Financial Years beginning on or after 1 January 2025. 

• Multinational Enterprise Top-up Tax (MTT) (also known as the Income Inclusion Rule or IIR under the Global Anti-Base Erosion (GloBE) Model Rules) applies to low-taxed profits of group entities located outside Singapore.
• Domestic Top-up Tax (DTT) applies to low-taxed profits of group entities located in Singapore.

The above taxes aim to ensure that large Multinational Enterprise (MNE) groups are subject to a minimum effective tax rate of 15% under Pillar Two of the Base Erosion and Profit Shifting (BEPS) 2.0 initiative and are imposed under the Multinational Enterprise (Minimum Tax) Act 2024 (“MMT Act”).

Under the MMT Act, all in-scope MNE groups are required to register for MTT, DTT, and the filing of the GloBE Information Return (“GIR”). The registration process will begin in May 2026. 

The following information is provided to help MNE groups prepare for registration.

An MNE group is required to be registered under the MMT Act if all the following conditions are met:

• The MNE group has annual revenue of €750 million or more, as reported in the consolidated financial statements of the Ultimate Parent Entity (UPE) for at least two out of the four preceding financial years; and
• The MNE group has at least one Constituent Entity (CE) or a Joint Venture located in Singapore, or at least one Reverse Hybrid Entity that is incorporated or registered in Singapore.

Please prepare the following information before your submission to ensure a smooth registration process:

• Tax identification number (“TIN”) of all entities of the MNE group that are incorporated, registered or located in Singapore:
  • CEs (including Permanent Establishments);
  • Joint Ventures and Joint Venture subsidiaries;
  • Minority-owned CEs;
  • Investment entities or insurance investment entities;
  • Reverse Hybrid Entities; and
  • Excluded Entities 
• If the MNE group has more than 30 in-scope entities and/or more than 30 excluded entities, please complete and upload the following templates in the registration form instead of entering the details line by line in the form. 
  • Template for more than 30 in-scope entities (XLXS, 39KB)
  • Template for more than 30 excluded entities (XLXS, 36KB)
• For each entity of the MNE group, provide its TIN, jurisdiction of tax residency and the date of change in tax residency. This requirement applies only to entities incorporated or registered in Singapore that had shifted their tax residency from Singapore to a foreign jurisdiction after 30 November 2021.
• TIN and name of the CE located in Singapore to be appointed as both:
  • the Designated Local GloBE Information Return (GIR) Filing Entity (GFE); and 
  • the Designated Local DTT Filing Entity (DFE).
• Name, designation and contact details of the contact person of the GFE and the DFE.
• Start and end dates of the MNE group’s first Financial Year to which the MMT Act applies.

For further guidance, please refer to the Explanatory notes to registration form (PDF, 249KB).

We will process your registration within one month from receiving complete information. The processing time may take longer if there is incomplete information.

Upon receipt of the registration form, we will send an email notification to the UPE or, where applicable, the UPE’s appointed representative. When the registration is approved, we will mail letters of notification on the registration to the following entities:

DTT

• All CEs, joint ventures, joint venture subsidiaries and excluded entities located in Singapore, including the CE designated as the GFE and the DFE.
• All reverse hybrid entities registered or incorporated in Singapore.

MTT (if applicable)

• All responsible members located in Singapore. A responsible member refers to:
  • the UPE of the MNE group that is not an excluded entity;
  • an intermediate parent entity of the MNE group if no other member of the MNE group that owns a controlling interest in the entity is a responsible member (e.g. the UPE); or
  • a partially-owned parent entity of the MNE group if it is not wholly-owned by another partially-owned parent entity of the MNE group that is a responsible member.

A 10% surcharge on DTT and MTT (if applicable) may be imposed if an in-scope MNE group fails to notify the Comptroller of its registration liability under the MMT Act.

If you have any questions on Pillar 2 Registration matters, please contact us at [email protected].