Demystifying Pillar Two Elections: Strategic planning amid
US/G7 shifts

Understanding Pillar Two elections can be complex. From one-time and five-year elections, entity-level and jurisdiction-level choices, as well as election for Transitional Country-by-Country Reporting Safe Harbour (TCSH), each decision may carry significant implications. Even small missteps could lead to unexpected Pillar Two exposure.

As in-scope Multinational Enterprise (MNE) groups transition from or exit the TCSH, how should they strategise for Pillar Two elections? What are the common misconceptions to look out for?

Meanwhile, the US/G7 statement on Pillar Two – especially the removal of Section 899 in the One Big Beautiful Bill Act – raises new questions for Singapore subsidiaries of US-parented and other groups. What’s next for Domestic Top-up Tax (DTT) and Pillar Two compliance obligations?  

Join our upcoming webinar to dive into these critical developments and their implications for businesses in the changing global tax landscape.

Webinar highlights:

• Pillar Two elections: Find out the key elections undertaken by in-scope MNE groups, how they operate, common misconceptions, and the impact of making (and revoking) these elections.
• Compliance requirements for US-parented and non-US-parented MNE groups in Singapore: Learn the expected compliance requirements for DTT, Global Anti-Base Erosion Information Return, and the interaction of the US Net CFC Tested Income – previously known as Global Intangible Low-Taxed Income with DTT. Explore the possibility of an “elective DTT”, and what “substanced-based” non-refundable tax credits could cover.    
• Tax provisioning for DTT: How in-scope MNE groups should prepare for December year-end Singapore tax reporting – particularly the allocation of DTT liabilities amongst Singapore in-scope entities.

Be in Front of the evolving tax landscape with KPMG in Singapore. Ensure compliance as you prepare for Pillar Two's implementation today.