The Inland Revenue Authority of Singapore (IRAS) has announced a dedicated point of contact for taxpayer inquiries concerning the impending Global Anti-Base Erosion (GloBE) Rules and Singapore’s Domestic Top-up Tax (DTT).
This follows recent updates to the GloBE Rules and DTT section on the IRAS website. The updates reinforce Singapore’s commitment to implementing key components of the OECD/G20 Inclusive Framework’s Pillar Two model.
Key Implementation Details:
- Effective Date: The Income Inclusion Rule (IIR) and the Domestic Top-up Tax (DTT) will apply to in-scope multinational enterprise (MNE) groups for financial years commencing on or after 1 January 2025.
- Scope: The IIR and DTT will apply to MNE groups meeting the €750 million revenue threshold. This threshold is assessed based on the consolidated financial statements of the group’s Ultimate Parent Entity (UPE) for at least two out of the four immediately preceding financial years.
- Undertaxed Profits Rule (UTPR): Singapore has confirmed it will implement the IIR and DTT from 2025. A decision on implementing the complementary Undertaxed Profits Rule (UTPR) will be made at a later date.
Resources and Support:
To aid taxpayer understanding and preparation, IRAS has uploaded an informative set of presentation slides outlining key aspects of the GloBE Rules and DTT. Taxpayers are strongly encouraged to consult the foundational documents:
- OECD GloBE Model Rules
- OECD Commentary on the GloBE Rules
- OECD Administrative Guidance
IRAS has established a dedicated email channel for questions related to the GloBE Rules or the Singapore DTT:
- Email: IRAS_Pillar_Two@iras.gov.sg
Taxpayers and advisors are invited to utilize this contact for specific technical or clarificatory inquiries regarding the upcoming rules.
Source: IRAS, 7 May 2024.