Singapore Pillar Two Registration: What Multinational Groups Need to Do

Multinational enterprise (MNE) groups within Singapore’s Pillar Two scope must complete a one-time registration with the Inland Revenue Authority of Singapore (IRAS). The requirement applies from financial years beginning on or after January 1, 2025, with registration deadlines determined by each group’s financial year-end.

Which multinational groups must register?

An MNE group must register in Singapore if its annual consolidated revenue is at least EUR 750 million in at least two of the four financial years before the financial year being assessed.

The group must also have at least one constituent entity or joint venture located in Singapore, or at least one reverse hybrid entity incorporated or registered in Singapore.

Singapore introduced two Pillar Two taxes for financial years beginning on or after January 1, 2025:

• Multinational Enterprise Top-up Tax (MTT) applies to a parent entity in Singapore on low-taxed profits of group entities operating outside Singapore.
• Domestic Top-up Tax (DTT) applies to low-taxed profits of group entities operating in Singapore.

Registration may still be required even if no top-up tax is ultimately payable.

When is the registration deadline?

Registration must be completed within six months after the end of the MNE group’s first financial year covered by Singapore’s Multinational Enterprise (Minimum Tax) Act. Groups with different financial year-ends will therefore have different registration deadlines. For calendar-year groups whose first applicable financial year ended on December 31, 2025, the registration deadline was June 30, 2026. Groups that were required to register by this date but have not done so should address the outstanding registration with IRAS.

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IRAS has provided a separate process for MNE groups with a financial year of less than 12 months that both began and ended in 2025 and could not submit the registration within six months of that financial year-end. These groups can request an extension from IRAS.

Who registers the group and which Singapore entity is designated?

The ultimate parent entity (UPE) is responsible for notifying IRAS by submitting the group’s registration information.

An overseas UPE can submit the registration even if it does not have a Singapore Tax Identification Number. The UPE may also authorize an individual from a Singapore constituent entity or a local tax agent to submit the registration on its behalf. The representative must submit a Letter of Authorization from the UPE.

The group must also designate a Singapore constituent entity as both the:

• Designated Local GloBE Information Return Filing Entity (GFE); and
• Designated Local Domestic Top-up Tax Filing Entity (DFE).

The entity’s name and Tax Identification Number are provided during registration.

MTT filing is handled differently. An MTT return is filed by a Singapore parent entity that is responsible for the MTT liability under the rules.

What information is needed for registration?

IRAS also requires the start and end dates of the group’s first financial year covered by the MMT Act and information on the Singapore entity designated as the GFE and DFE.

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For certain entities incorporated or registered in Singapore that moved their tax residence from Singapore to another jurisdiction after November 30, 2021, the group must provide the entity’s Tax Identification Number, tax residence, and date of the change.

Where there are more than 30 in-scope entities or more than 30 excluded entities, IRAS provides templates that can be uploaded as part of the registration process.

What happens if the group does not register on time?

IRAS may impose a surcharge equal to 10 percent of the DTT and MTT payable, where applicable, if an in-scope MNE group fails to notify the Comptroller of Income Tax that it is required to register.

A group that has already submitted its registration but identifies an error should not submit a second registration. IRAS instructs groups to contact it with the acknowledgement number of the original submission so the error can be corrected.

IRAS generally processes complete registrations within one month. After successful registration, the MNE group receives a Group Identification Number for DTT and GloBE Information Return purposes.

What should multinational groups prepare for after registration?

A GloBE Information Return must also be filed. However, the group may be able to file it centrally in another jurisdiction if that jurisdiction has the required information-exchange agreement with Singapore.

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Singapore’s Pillar Two returns and GloBE Information Return are generally due within 15 months after the end of the relevant financial year. An 18-month period applies for the transition year.

Singapore also intends to amend its legislation by the end of 2026 to adopt relevant parts of the OECD’s January 2026 Side-by-Side package, subject to Parliament’s approval.

Contact Dezan Shira & Associates for Pillar Two compliance in Singapore

Dezan Shira & Associates can assist multinational groups in determining whether Singapore’s Pillar Two requirements apply, completing registration, identifying the appropriate filing entities, and managing subsequent MTT, DTT, and GloBE reporting obligations.

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