Singapore BEPS 2.0 Pillar Two: 15% global minimum tax and compliance requirements
BEPS Pillar Two establishes a global minimum effective tax rate of 15% for large multinational enterprise (MNE) groups. Developed under the OECD/G20 Inclusive Framework, the rules aim to ensure that profits are subject to a minimum level of taxation in each jurisdiction where the group operates.
Singapore has implemented these rules through the Multinational Enterprise (Minimum Tax) Act 2024 (MMT Act). The regime introduces new compliance obligations, including top-up taxes and reporting requirements for in-scope groups.
Under the Singapore framework, Multinational Enterprises (MNE) groups may be required to comply with:
- Multinational Enterprise Top-up Tax (MTT)
- Domestic Top-up Tax (DTT)
- GloBE Information Return (GIR)
These requirements will apply alongside existing corporate tax obligations and are expected to introduce additional data, reporting and governance considerations.
Registration requirement (from May 2026)
Singapore will introduce a one-time registration requirement for Pillar Two from May 2026. Registration deadlines are linked to the financial year end (FYE) of the Ultimate Parent Entity (UPE).
Who is required to register?
An MNE group is required to register in Singapore where both of the following conditions are met:
Revenue threshold
The group has consolidated annual revenue of at least EUR 750 million in the UPE’s financial statements for at least two of the four preceding financial years.
Singapore nexus
The group has at least one of the following in Singapore:
- A Constituent Entity (CE)
- A Joint Venture (JV) or JV subsidiary
- A Reverse Hybrid Entity (that is not a responsible member)
Registration timeline
Registration must be completed within 6 months after the end of the UPE’s first financial year to which the MTT or DTT applies.
Illustrative example
UPE financial year end: 31 December 2025
Registration deadline: 30 June 2026
Ongoing compliance obligations
Following registration, in-scope MNE groups are required to meet annual filing and reporting obligations.
Multinational Enterprise Top-up Tax (MTT)
The MTT applies under the Income Inclusion Rule to low-taxed profits of foreign constituent entities. Filing is generally undertaken by the Singapore-based responsible member.
Domestic Top-up Tax (DTT)
The DTT applies to Singapore constituent entities to ensure a minimum effective tax rate of 15% on local profits. Filing is typically undertaken by a Designated Filing Entity.
GloBE Information Return (GIR)
The GIR is a standardised reporting requirement under the OECD framework. An MNE group may rely on a GIR filed in another jurisdiction where:
- The return is filed in that jurisdiction; and
- Singapore has a qualifying automatic exchange arrangement in place
Filing and payment timelines
Filing deadlines
- Within 15 months after the UPE’s FYE
- Extended to 18 months for the first year of application
Payment deadlines
- Within 1 month after the filing due date
Illustrative timeline (UPE FYE: 31 December 2025)
- Filing deadline: 31 March 2027
- Transition year filing deadline: 30 June 2027
- Payment deadline: 30 April 2027
- Transition year payment deadline: 31 July 2027
Key considerations for MNE groups
The Pillar Two rules introduce a significant level of complexity. In particular:
- Effective Tax Rate (ETR) calculations require new and granular data points
- Groups may need to adapt systems and processes to capture required information
- There may be increased compliance and reporting obligations across jurisdictions
- Early assessment can help manage implementation timelines and risks
Many groups are not currently collecting the level of data required for GloBE reporting and may need to evaluate their readiness.
How Forvis Mazars can help
Forvis Mazars supports MNE groups in navigating the complexities of BEPS Pillar Two, including:
- Assessing whether the rules apply to your group
- Supporting registration readiness and submission
- Assisting with MTT, DTT and GIR compliance
- Advising on ETR calculations and data requirements
- Reviewing and enhancing systems, processes and governance frameworks
Our approach is tailored to the specific structure and needs of each group.
Download our Pillar Two brochure
Learn more about:
- Who needs to register
- Key requirements and timelines
- Practical steps for compliance
Download the BEPS Pillar Two brochure
Contact us
If you would like to discuss how the Singapore Pillar Two rules may apply to your organisation, please contact your dedicated Forvis Mazars adviser or reach out to our team.
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