The 7 May 2026 notes
These eight pages explain registration of an MNE group under the Multinational Enterprise (Minimum Tax) Act 2024. They distinguish the global transition year, Singapore’s first tested financial year, MTT registration, domestic filing appointments and the full entity list. Group and UPE names must match those used or expected in the GloBE Information Return (GIR).
Transition year can precede Singapore implementation
The transition year is the first year within a qualified IIR or UTPR anywhere, or liability to register for Singapore MTT/DTT, whichever is earlier. In both examples a foreign UPE or a foreign intermediate parent enters a qualified IIR in 2024. The group’s transition year remains 1 January–31 December 2024 even though Singapore implemented MTT/DTT in 2025. Do not automatically enter 2025 solely because the UPE is Singaporean.
Registration threshold and first tested year
Annual UPE consolidated revenue must reach EUR750 million in at least two of the four financial years immediately before the tested year, with a Singapore constituent entity or JV, or a Singapore-incorporated/registered reverse hybrid. First tested years commence on or after 1 January 2025 and follow the UPE’s consolidated accounting period: December year-end tests January–December 2025; March tests April 2025–March 2026; June tests July 2025–June 2026; September tests October 2025–September 2026.
Deemed consolidation and multi-parent groups
Where the UPE prepares consolidated financial statements, answer No to deemed consolidation. Otherwise answer Yes and assess statements that would be required under an authorised acceptable standard, or an adjusted standard preventing material competitive distortion. A formal combination of two or more UPE-led businesses may create one multi-parent MNE group despite separate ownership. The form accommodates three UPEs; send names, TINs and jurisdictions from the fourth onwards to IRAS_PillarTwo_Compliance@iras.gov.sg.
UPE identity and location
For a Singapore UPE use its ACRA UEN or IRAS ASGD number for a foreign-incorporated entity. For a foreign UPE use the GIR TIN or the expected GIR TIN if not yet filed. A non-flow-through UPE is located by tax residence; where it has none, use the jurisdiction of establishment, formation, incorporation or registration. A flow-through UPE uses that legal formation jurisdiction. Apply section 5 for further location detail.
Year-end: all four examples and changed periods
A twelve-month year-end uses a month and date: 31 December or 15 June in the first two examples. A 52/53-week year-end may use the last Sunday of December: the illustrated period runs 29 December 2025–27 December 2026, with Sun/Dec and the form’s “Last day of the month” choice. Alternatively choose the Sunday nearest 31 December: 29 December 2025–3 January 2027, with Sun/Dec/31. If a change creates a longer or shorter period, enter the new year-end; changing December 2025 to March 2026 means entering 31 March.
MTT and responsible members
MTT concerns a Singapore parent’s interests in relevant foreign and stateless entities, not its interests in Singapore entities. Register where a Singapore parent is a responsible member. Categories include a non-excluded UPE, an intermediate parent without another controlling responsible member, and a partially-owned parent not wholly owned by another responsible partially-owned parent. Sections 13(2) and 13(3) impose additional conditions.
The IPE and POPE ownership example
A UPE outside qualified IIR owns Singapore A entirely and 70% of Singapore B; an outside-group Z owns B’s remaining 30%. A and B wholly own foreign C and D. Registration is Yes: enter A as IPE and B as POPE, since more than 20% of B is outside-group owned. Reasons for no MTT registration can include no Singapore responsible member, no Singapore parent, or a foreign intermediate entity’s IIR switching off Singapore MTT.
DFE, GFE and authorised contacts
Designate the SAME Singapore constituent entity as domestic DTT filing entity (DFE) and local GIR filing entity (GFE). Its contact must be a specifically identified individual authorised by the DFE; additional contacts go in Other Comments. The UPE makes appointments for Singapore CEs, connected Singapore JVs/JV subsidiaries and the specified Singapore reverse-hybrid flow-through entities. Appointment rules are further explained in the MTT/DTT guide.
Every in-scope entity, including those disposed of
List Singapore CEs including permanent establishments and partly owned CEs, JVs/JV subsidiaries, minority-owned subgroup members and CEs, and Singapore-formed reverse hybrids that are not responsible members. Enter UPE/IPE/POPE status even if not a responsible member. Include entities consolidated during the tested year but disposed of or liquidated before year-end. For ceased CEs put TIN, cessation details and effective date in Other Comments. Over thirty in-scope entities use the accompanying template.
Excluded entities and residency changes
Excluded entities are normally outside MTT/DTT, but a five-year GIR election to treat them as CEs means including them in the in-scope list. Over thirty excluded entities use their separate template. For Singapore-incorporated/registered entities that moved tax residence overseas after 30 November 2021, the section excludes Singapore branches. If more than thirty moved, email the additional TINs, residency jurisdictions and change dates from the thirty-first onwards.
Who submits and the authorisation letter
A UPE director or senior officer, such as CEO, controller, vice-president or tax-return signatory, may submit directly. A representative may be a Singapore CE or local tax agent and must attach a letter on UPE letterhead: representative organisation’s name/address, authority to submit and act for BOTH UPE and group on registration, and UPE director/senior-officer signature. Naming the organisation suffices without naming a specific individual in the letter. A duly UPE-authorised person may also be the DFE contact. Use Other Comments for additional registration information.
Official source
This article independently explains the substantive contents of the official PDF, including the relevant conditions, procedures and annexes. The linked document remains the authoritative source for its original wording, and later changes should be checked separately.
Read the official PDF ↗