The first Pillar Two filing season may be over, but FY2025 brings new compliance challenges.
Groups already in scope for FY2024 will have a shorter GloBE Information Return (GIR) filing window of 15 months instead of 18. Many filing extensions and penalty concessions from the first season will not apply, while the Under Taxed Profits Rule (UTPR) introduces additional complexity. In Singapore, FY2025 is also the first year of the Multinational Enterprise Top-up Tax (MTT) and Domestic Top-up Tax (DTT).
The OECD/G20 Inclusive Framework’s September 2026 package adds further considerations, including:
- Administrative Guidance on Explicitly Conditional Taxes and the use of local financial accounting standards for Qualified Domestic Minimum Top-up Tax (QDMTT).
- An updated GIR reflecting the January 2026 Side-by-Side Package.
- A new Full Legislative Review process that replaces transitional self-assessed qualified status with formal peer review.
What do these developments mean for your FY2025 compliance? Which GIR requirements apply, could your Covered Tax treatment change, and how might the Full Legislative Review affect reliance on the QDMTT Safe Harbour? With Singapore’s first DTT, MTT and GIR filings approaching, what should your group do now?
Join our upcoming webinar to understand the changes, their practical implications and the steps your group should take now.
Webinar highlights:
- September 2026 Administrative Guidance: Understand when an Explicitly Conditional Tax may be excluded from Covered Taxes, and how the local financial accounting standards rule applies where constituent entities and the ultimate parent entity have different financial year-ends, including during acquisitions, disposals and mergers.
- Updated GIR: Explore new reporting requirements for Government Benefits and Qualified Tax Incentives, reduced disclosures for eligible US-parented groups under the Side-by-Side Safe Harbour, and new elections and data points for the Simplified ETR and Substance-based Tax Incentive Safe Harbours. We will also clarify which parts of the revised GIR may affect FY2025 filings.
- Full Legislative Review: Learn how jurisdictions’ Pillar Two legislation and filing requirements will be assessed against the agreed GloBE Rules, and what a loss of qualified status could mean for groups relying on the QDMTT Safe Harbour.
- FY2025 practical compliance: Work through the application and allocation of the UTPR using practical scenarios. We will also cover preparations for Singapore’s first MTT, DTT and GIR filing cycle, including CorpPass authorisation and filing and payment through the IRAS myTax Portal.
Be in Front of the evolving tax landscape and prepare for Pillar Two’s second compliance season with KPMG.
