Global Daily Tax News, Singapore Begins Registering MNEs For Pillar Two Taxes, (May 12, 2026)

The Inland Revenue Authority of Singapore has begun registering multinational enterprise groups under the Multinational Enterprise (Minimum Tax) Act 2024.

Singapore introduced a regime under Pillar Two of the OECD's two-pillar international tax reform for financial years beginning on or after January 1, 2025, by introducing two levies:

• A Multinational Enterprise Top-up Tax (MTT), which implements the Income Inclusion Rule under Pillar Two, enabling Singapore to tax the undertaxed profits of Singapore-headquartered MNEs arising overseas to the minimum 15-percent rate; and

• A Domestic Top-up Tax (DTT), which is intended to ensure that multinational groups in scope of Pillar Two are subject to a minimum tax rate of at least 15 percent in Singapore.

In-scope MNE groups are required to register for MTT, DTT, and the filing of the GloBE Information Return (GIR), with IRAS announcing that this process has begun as of May 11, 2026. 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 EUR750m or more, as reported in the consolidated financial statements of the Ultimate Parent Entity (UPE) for at least two out of the four financial years immediately preceding the tested FY; 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.

Registration should be carried out by completing a newly released online registration form.

IRAS said: "The registration form must be submitted within six months after the end of the group's first financial year to which the MMT Act applies. For example, the MNE group's first financial year to which the MMT Act applies is January 1, 2025, to December 31, 2025. The MNE group must submit the registration form by June 30, 2026 (that is, six months from the group's FYE of December 31, 2025).

IRAS has also announced an email address that can be used by MNE groups with a financial year of less than 12 months starting and ending in 2025 to seek an extension if they are unable to submit the registration form within six months after its financial year end. This email should include the subject header "Request for extension for registration under the MMT Act", IRAS said.

The IRAS further advised taxpayers: "If the UPE wishes to appoint a representative to register the MNE group on its behalf, the representative (that is, an individual) may be either from a CE of the MNE group located in Singapore or a local tax agent."

"The representative appointed by the UPE must submit the registration form together with a Letter of Authorisation. This letter, issued on the UPE's company letterhead, must explicitly state that the representative's organisation is authorised to submit the registration form and to act on behalf of both the UPE and the MNE group in all registration-related matters," IRAS said.

IRAS has issued guidance on the registration process, what information must be submitted, and what happens after a registration form is submitted.