The long-awaited Side-by-Side (“SbS”) package has finally arrived! Under the SbS system, US-parented groups will have both the SbS and Ultimate Parent Entity (“UPE”) safe harbours applied. What does this mean for Domestic Top-up Tax?
In addition, Transitional Country-by-Country Reporting Safe Harbour (“TCSH”) has been extended for another year. Subsequently, the Simplified Effective Tax Rate (“ETR”) Safe Harbour, which is a permanent safe harbour, will become available. How does this Simplified ETR Safe Harbour compare against the Simplified ETR Test under TCSH?
The Organisation for Economic Co-operation and Development’s January 2026 Administrative Guidance also includes the release of a Substance-based Tax Incentives Safe Harbour, where expenditure-based and certain production-based tax incentives would provide a more favourable ETR outcome for recipients. Is this the same as a Qualified Refundable Tax Credit (“QRTC”)?
Join our upcoming webinar to dive into these critical developments and their implications for businesses in the changing global tax landscape.
Webinar highlights:
- SbS System: Find out what is considered an eligible tax regime recognised by the Inclusive Framework, and how the SbS and UPE Safe Harbour will apply for US-parented groups. What about groups parented elsewhere?
- TCSH vs Simplified ETR Safe Harbour: Understand the differences between the current Simplified ETR test under TCSH and the Simplified ETR Safe Harbour, which is a permanent safe harbour.
- Substance-based Tax Incentives Safe Harbour: Find out how the ETR calculation works under this safe harbour versus the QRTC, and whether (and how) existing tax incentives in Singapore would qualify.
- Elections: Wrapping up our series on Pillar Two elections, we will cover the remaining significant elections, such as the immaterial decrease in covered taxes election, negative tax expense carry-forward election, and unclaimed accrual election.
With KPMG, you can Be in Front of the evolving tax landscape and ensure compliance as you prepare for Pillar Two's implementation.
