Singapore Tax Agency Updates Guidance on MNE, Domestic Top-Up Tax Registration Requirements Under Pillar 2

May 11, 2026, 5:00 AM UTC

The Singaporean Inland Revenue Authority May 7 updated guidance on the registration and filing requirements for the multinational enterprise (MNE) top-up tax (MTT) and domestic top-up tax (DTT) under OECD Pillar Two. The guidance provides that: 1) MNE groups with annual consolidated revenue of 750 million euros (US$881.9 million) or more and at least one constituent entity in Singapore, or at least one reverse hybrid entity incorporated or registered there, must register for MTT, DTT, and file Global Anti-Base Erosion (GloBE) Information Returns (GIRs); 2) for DTT return and GIR filing purposes, an MNE’s DTT filing entity (DFE) or GIR ...

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