Singapore: Bills to implement global minimum tax; list of jurisdictions for exchange of CbC reports; applying for certificates of residence
Parliament passed bills to implement the multinational enterprise top-up tax and the domestic top-up tax
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November 20, 2024
Tax developments in Singapore include the passage of bills by Parliament to implement a global minimum tax, updates by the Inland Revenue Authority of Singapore (IRAS) to the list of jurisdictions for country-by-country (CbC) reporting, and new guidance on applying for certificates of residence.
- Parliament passes bills to implement global minimum tax: Parliament in October 2024 passed two bills to implement the multinational enterprise top-up tax (MTT) and the domestic top-up tax (DTT) to ensure a minimum effective tax rate of 15%. These amendments will apply to multinational enterprise (MNE) groups in Singapore starting January 1, 2025, aligning with the OECD/G20's global anti-base erosion model rules (Pillar Two).
- Updated list of jurisdictions under CbC reporting: The IRAS in October 2024 updated the list of jurisdictions for the exchange CbC reports under the Multilateral Competent Authority Agreement on Automatic Exchange of Country-by-Country Reports (2016), effective January 1, 2024. This update includes the addition of Albania and Georgia to the list of jurisdictions.
- Guidance on applying for certificates of residence: The IRAS has published updated guidance on applying for a certificate of residence and tax reclaim form. The update concerns additional requirements from 2025 for foreign-owned investment holding companies.