Singapore Pillar Two Registration Process January 2026

Summary

In October 2024, The Parliament of Singapore passed the Multinational Enterprise (Minimum Tax) Act,2024 (MMT Act). The provisions of the act are applicable from the financial year starting on or after 1^st January 2025. The MMT Act requires MNE groups that meet the applicability criteria to register the group.

In line with the above requirements, The Inland Revenue Authority of Singapore (IRAS”) has released the draft registration form and process for submitting the form’. Registration is expected to start from May 2026. Failure to register may result in a 10% surcharge on any applicable tax payable under the MMT Act.

The Ultimate Parent Entity can appoint a subsidiary or a local tax agent to act as its representative. Registration requires disclosure of all entities operating in Singapore and their classification in accordance with the MMT Act. The details on the applicability and contents of the registration form are provided below.

Applicability

1. Introduction

The OECD/G20 Inclusive Framework introduced measures to limit base erosion and prevent large multinational enterprises (MNEs) from shifting profits to low- tax jurisdictions, through BEPS Action Plans. As a continuum of this initiative, Pillar Two rules were introduced, aiming at minimum effective tax rate of 15% in each jurisdiction.

As part of Inclusive Framework, Singapore has enacted the Multinational Enterprise (Minimum Tax) Act 2024 (MMT Act), This Act introduced two key provisions:

• Multinational Enterprise Top- Up Tax (MTT) – the local implementation of the Income Inclusion Rule (IIR) under Pillar 2.
• Domestic Top- Up Tax (DTT) – Singapore’s equivalent of the Qualified Domestic Minimum Top- Up Tax (QDMTT).

Under the MMT Act, an MNE group is considered in- scope if it meets both of the following criteria:

1. The group has an annual consolidated revenue of €750 million or more for its Ultimate Parent Entity (UPE) in at least two of the four preceding financial years.
2. The group has at least one Constituent Entity (CE) or Joint Venture located in Singapore, or at least one Reverse Hybrid Entity that is incorporated or registered in Singapore.

These rules ensure that Singapore- based entities within large MNE groups comply with global minimum tax standards while maintaining alignment with the OECD/G20 Pillar 2 framework.

2. Registration Requirement

The UPE of an in- scope MNE group must register for the MMT Act within six months after the end of the first financial year to which the Act applies. The online registration form will be available from May 2026. For UPEs with a calendar year 2025 as their accounting year, the registration deadline is 30 June 2026. For UPEs with a financial year ending March 2026, the registration deadline is 30 September 2026.

UPE can designate a local Constituent Entity or appoint a local tax agent to register the group. A letter of Authorization, explicitly authorizing the representative to act on behalf of UPE, must be attached with the registration form.

Additionally, the UPE must designate a single Singapore CE as the Designated Local DTT filling entity as well as GloBE Information Return (GIR) filing entity.

If the MNE group only has excluded entities operating in Singapore, registration is not required, provided these entities are correctly treated as excluded entities in the GIR.

In the event of errors discovered after submission, IRAS recommends not re- submitting the form. Instead, the UPE should notify IRAS by email with the subject title as “Correction to Registration From <acknowledgment number of the original submission>, along with group/UPE name, UPE TIN, details of the incorrect entries, and the required amendments.

3. Information Required for Registration

The following are the details to be included in the registration form.

In the end IRAS requires the Ultimate Parent Entity (“UPE”) to declare that the information provided in the registration form is true and complete. Penalties are attracted for an incorrect declaration.

Where errors are identified after submission, the registration form should not be re- submitted. Instead, UPE is required to notify IRAS by email.

Post Registration

IRAS will acknowledge receipt by email and typically process within ~1 month (longer if information is incomplete). Upon approval, letters will be sent to Singapore- located CEs/JVs/JV- subs/excluded entities and reverse hybrids, and to responsible members for MTT (if applicable).

Non-compliance Consequence

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

Conclusion

Currently over 55 jurisdictions have implemented Pillar Two rules in their tax laws, including traction among several other jurisdictions w.r.t. implementation of GloBE rules. In several mature tax jurisdictions, effective financial year for which Pillar Two is effective has concluded and the timelines for various compliances w.r.t. GloBE rules would fall in 2026.

In Singapore, the IRAS has notified the Registration requirement for applicable MNE Groups. Registration requires information to be provided about the MNE group including details of the UPE, CEs, designated filing entity. This registration should not be viewed simply as a simple form filling exercise. Rather, it would require wholistic understanding of the impact of GloBE rules on the Group, to correctly provide information in the registration form. Further, as there is surcharge on non- compliance of registration, MNE Group would have to be Pillar Two ready.

How VSTN can support

VSTN offers support on Pillar Two including:

• Impact & readiness assessments: Scoping, safe harbour eligibility, and jurisdictional ETR modelling
• Technical interpretation & advisory: GloBE income, covered taxes, deferred tax adjustments, QDMTT design, quantifying top- up tax liability and alignment with transfer pricing, CbCR and overall tax strategy.
• Data, systems, and process support: Data gap analysis, calculation models and updating accounting and reporting systems.
• Compliance and reporting assistance: GloBE calculations, GIR / QDMTT returns and related disclosures in financial statements.
• Governance, audit, and controversy support: Documentation and internal controls
• Ongoing regulatory monitoring: Tracking OECD guidance and local law developments and assessing client- specific impact.