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Taxes · PDF

Pillar Two Training: IIR, UTPR and QDMTT Rule Order

Part A of Module One, second edition June 2026, introduces BEPS 2.0, the Glo BE rules and domestic minimum top-up tax. Although the outline lists Singapore implementation, scope and charging provisions, this particular Part A ends after the overview. It does not state the group revenue threshold or provide the full Singapore charging calculation.

Source checked · 11 October 2026

What this twenty-slide module covers

Part A of Module One, second edition June 2026, introduces BEPS 2.0, the Glo BE rules and domestic minimum top-up tax. Although the outline lists Singapore implementation, scope and charging provisions, this particular Part A ends after the overview. It does not state the group revenue threshold or provide the full Singapore charging calculation.

Pillar One and Pillar Two have different functions

The Inclusive Framework agreed the two-pillar solution on 8 October 2021. Pillar One reallocates taxing rights over residual profits to market jurisdictions. Pillar Two permits top-up taxation where income is untaxed or taxed at a low level. Within Pillar Two the slides distinguish the Subject-to-Tax Rule from the Glo BE IIR/UTPR and the QDMTT.

A common approach rather than universal adoption

Members adopting Glo BE must implement outcomes consistently with the rules. Members that do not adopt must nevertheless accept other members applying the rules to multinational groups operating in their jurisdictions. Non-adoption therefore does not by itself shelter a group from foreign top-up taxation.

Development of the reference materials: 2021–2023

The timeline starts with December 2021 Model Rules, March 2022 Commentary and December 2022 safe-harbour/penalty-relief report. February 2023 guidance addressed scope, income/tax calculations, transition and QDMTT design. July 2023 added the Information Return and guidance on currency conversion, credits, substance exclusion and safe harbours. December 2023 covered Transitional Cb CR Safe Harbour and blended CFC-tax allocation.

Development of the reference materials: 2024–2026

April 2024 consolidated the commentary through December 2023 and updated examples. June 2024 addressed deferred-tax-liability recapture, cross-border current/deferred-tax allocation and securitisation vehicles. January 2025 updated the Information Return, transitional qualified-status central record, Articles 8.1.4/8.1.5 and Article 9.1 guidance. May 2025 consolidated commentary through January and updated examples; January 2026 added Side-by-Side Package guidance. These dates identify editions, not a complete list of all later updates.

Order: domestic minimum tax, IIR, then UTPR

QDMTT first tops up low-taxed constituent entities in their own jurisdiction, on a jurisdictional basis, to the fifteen-percent minimum. IIR then taxes the relevant parent for low-taxed entities, deducting QDMTT already paid. UTPR is the backstop for top-up not fully collected through IIR. The order prevents multiple jurisdictions taxing the same low-taxed profits without adjustment.

IIR: top-down collection and both diagrams

IIR generally operates from the top of the holding structure. Example 1 has a UPE in jurisdiction A, which implements IIR, owning a foreign subsidiary in B one hundred percent: A collects at the UPE. Example 2 has a UPE in C without IIR, an intermediate parent in D with IIR and a subsidiary in E, each link one hundred percent: the intermediate parent in D applies IIR. The diagram illustrates the relevant collecting parent, without quantifying tax.

UTPR: the diagram assigns B’s shortfall to C

The UPE in A has neither IIR nor UTPR. It owns subsidiaries B and C one hundred percent; B’s jurisdiction has no UTPR but C’s implements UTPR. The diagram allocates subsidiary B’s top-up tax to subsidiary C. More generally, implementing constituent-entity jurisdictions collect using a substance-based allocation key. The slides do not give that key’s numerical weights.

QDMTT: local collection and the two contrasting examples

QDMTT taxes low-taxed income domestically and is deductible against IIR or UTPR top-up. In example 1 the subsidiary in B applies QDMTT, reducing IIR top-up at its parent in A. In example 2 the subsidiary in D has no QDMTT, so its UPE in C applies IIR. Both diagrams show full ownership. They illustrate priority, not an exemption from other filing obligations.

Reading the terminology and presentation date

UPE is ultimate parent, IPE intermediate parent, CE constituent entity and QDMTT qualified domestic minimum top-up tax. MTT and DTT are Singapore’s multinational-enterprise and domestic top-up tax terms; the abbreviation list also distinguishes the 2024 Act/Regulations from the 2025 administrative regulations. The closing slide limits the presentation to general understanding as at its date. Consult the linked official learning page for edition updates before applying later modules.

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.

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