Inland Revenue Authority of Singapore updated its e-Tax Guide on the multinational top-up tax and domestic top-up tax on January 7, 2026. The update confirms that Singapore’s Minimum Tax Act is treated as a qualified income inclusion rule and a qualified domestic minimum top-up tax from January 1, 2025. It also clarifies how group revenue is calculated to check the €750 million threshold and updates guidance for reverse hybrid entities.
The e-Tax Guide can be accessed , here.
Singapore has updated its e-Tax guide on transfer pricing. The new guidance clarifies that taxpayers can’t rely on old TP documentation unless they file the required declarations for simplified documentation. Taxpayers must also be able to justify when gains, losses, or deductions are treated as capital for TP adjustments. The update sets out the procedures and obligations for MAP and APA applications and explains how profits should be attributed to permanent establishments under the arm’s-length principle. Singapore also plans to introduce the OECD optional simplified and streamlined approach for certain transactions from 2026 to 2028.
To access the e-Tax Guide, click here.
In December 2024, Singapore’s tax administration issued regulations and a guidebook to help companies comply with its global minimum tax law. The regulations, published in the legislative gazette on Monday, provide instructions for calculating top-up tax amounts, determining the first year a company falls under the rules, and handling transferable tax credits. They also specify how and when to convert income into Singapore dollars or euros. On Tuesday, a simplified guide was released, explaining the scope of the law, along with carve-outs and safe harbors under Pillar Two of the OECD’s global tax framework. Starting January 1, 2025, Singapore will implement two of the three Pillar Two rules: a domestic top-up tax and a multinational enterprise top-up tax (Singapore’s version of the income inclusion rule), ensuring multinational companies face a minimum 15% tax rate.
To read more on the regulations, click here.