The US stance on Pillar 2 aims to shield both its Multinational Enterprise (MNE) Groups and local entities of foreign MNEs from top-up taxes. In the “One Big Beautiful” bill–the latest House Republicans’ reconciliation tax bill–there is a new tax code, Section 899, which targets jurisdictions imposing an “unfair foreign tax”. This has major implications for Singapore and other foreign parented MNE groups – how will global tax policy react as a whole?
Meanwhile, as the first Domestic Top-up Tax return deadline looms in November for Belgium, tax leaders are racing to prioritise compliance efforts for Pillar 2. MNE Groups with Ultimate Parent Entities (UPEs) in jurisdictions across Singapore, US and China are asking – where should the GloBE Information Return (GIR) be filed centrally, and how does this interact with the ongoing Pillar 2 registration process?
Join our upcoming webinar as our KPMG in Singapore tax experts unpack what Section 899 means, how Pillar 2 could evolve to accommodate US demands, and what businesses should do to stay compliant.
Webinar highlights:
- Section 899 and “unfair foreign tax”: Understand what it covers and how the US may impose retaliatory tax rates and expand its base erosion and anti-abuse tax to target affected entities.
- Reconciling Pillar 2 with US tax policy: Explore proposed compromises that preserve both US interests and the sovereignty of implementing jurisdictions.
- Compliance and reporting: Get insights from the first draft Domestic Top-up Tax return released in Belgium, guidance on GIR centralised filing if your UPE jurisdiction has not adopted Pillar 2 in FY2024, and learn how it affects your ongoing Pillar 2 registrations.
With KPMG in Singapore, you can Be in Front of the evolving tax landscape and ensure compliance as you prepare for Pillar 2's implementation.
