What this three-page update contains
The June 2026 second-edition change log covers all eight e-learning modules for multinational enterprise top-up tax and domestic top-up tax. It is an index of amendments, not the complete revised computational rules or the new example itself. The relevant 2025 Amendment Act and Amendment No. 2 Regulations are repeatedly identified as the legislative sources.
Module 1: scope and charging
The document list now includes the OECD/G20 Side-by-Side package administrative guidance published 5 January 2026. It clarifies transitional qualified status of Singapore’s Minimum Tax Act 2024 and recognition of MTT and DTT as qualified IIR and QDMTT respectively from 1 January 2025. It adds Administrative Matters Regulations 2025 gazetted 30 December 2025, changes to reverse-hybrid-entity definition and consolidated-revenue adjustments, and other 2025 legislative changes.
Module 2: income and loss
The revision changes flow-through-entity definitions and financial-accounting net income or loss of FTEs and constituent-entity owners, introducing reference entities. It also updates portfolio-shareholding definitions and excluded equity gains or losses. These affect the income computation rather than merely renaming a reporting field.
Module 3: adjusted covered taxes
Changes cover qualifying foreign tax credits and relevant foreign income, special foreign tax assets, divergence between GloBE and accounting values, recaptured deferred-tax liabilities, unclaimed-accrual elections and definition, reallocation of reverse-hybrid taxes, and caps on controlled-foreign-company and reverse-hybrid taxes. Other 2025 changes are also incorporated.
Module 4: ETR and top-up amount
The top-up formula is amended for constituent entities with additional current top-up amounts attributable to section 21(4) recalculation for more than one previous financial year. A new example illustrates those calculations. This change log announces the example but does not print its numbers; do not fabricate an example and attribute it to this PDF.
Module 5: transition
The transition-year definition changes, alongside exclusions in certain circumstances for pre-regime deferred-tax assets or liabilities and other 2025 amendments. Determine whether a balance is excluded rather than assume every opening deferred-tax amount survives transition.
Module 6: all three safe-harbour changes
Transitional CbCR Safe Harbour simplified income-tax expense excludes deferred-tax expense from certain pre-regime deferred-tax balances. QDMTT Safe Harbour gains two disqualifying conditions concerning securitisation entities and certain pre-regime deferred-tax balances. Simplified Calculations Safe Harbour clarifies the top-up amount involving additional current top-up amounts. These are distinct changes to different safe harbours.
Modules 7 and 8
Corporate restructuring and holding-structure updates change relevant-MNE-group definitions for demergers, multi-parent-group definitions and their treatment. Tax-neutrality updates change relevant-owner definitions for FTEs and FANIL provisions for FTE ultimate parents, their permanent establishments and PEs of certain FTEs. Both modules also incorporate other 2025 legislative changes.
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 ↗