[T-SG] A Practical Guide to BEPS 2.0 Two-Pillar Registration

INTRODUCTION

Based on BEPS 2.0 Registration requirements for preventing base erosion and profit shifting published by IRAS, the following is a summary of important points to note regarding registration:

- Entities Who Are Required to Register

- Registration Deadlines

- Requirements for Applicants

- Expected Processing Time for Registration Applications by IRAS

- Surcharge for failure to notify

MAIN BODY

BEPS 2.0 is an international tax reform framework led by the OECD (Organisation for Economic Co-operation and Development). It primarily addresses the issue of multinational corporations ("MNE group") using differences in tax rates across countries to shift profits to low-tax jurisdictions, thereby reducing their tax burden. Singapore officially implements BEPS 2.0 Pillar Two Rules from 2025 onwards (applicable to FY2025 and beyond), incorporating the world's lowest tax regime into its local tax system.

Entities Who Are Required to Register

An MNE group is required to be registered under the MMT Act if all the following conditions are met:

• The MNE group has annual revenue of €750 million or more, as reported in the consolidated financial statements of the Ultimate Parent Entity (UPE) for at least two out of the four preceding financial years; and

• The MNE group has at least one Constituent Entity (CE) or a Joint Venture located in Singapore, or at least one Reverse Hybrid Entity that is incorporated or registered in Singapore.

Of which, the determination of a CE is mainly based on whether it falls within the scope of the group's consolidated financial statements. A Reverse Hybrid Entity usually refers to an entity that has a see-through/flow-through characteristic in terms of law or taxation.

Registration Deadlines

The registration form must be submitted within 6 months after the end of the group's first financial year to which the MMT Act applies. For example, the MNE group's first financial year to which the MMT Act applies is 1 January 2025 to 31 December 2025.The MNE group must submit the registration form by 30 June 2026 (i.e. 6 months from the group’s FYE of 31 December 2025).

Requirements for Applicants

If the UPE wishes to appoint a representative to register the MNE group on its behalf, that representative can be either a CE of the MNE group located in Singapore or a local tax agent.

Expected Processing Time for Registration Applications by IRAS

IRAS will process your registration application within one month of receiving complete information. Processing time may be longer if the information is incomplete.

Surcharge for failure to notify

A 10% surcharge on DTT and MTT (if applicable) may be imposed if an in-scope MNE group fails to notify the Comptroller of its registration liability under the MMT Act.

For further tax advice and cooperation inquiries, please feel free to contact us.

ABOUT ESTAR

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DISCLAIMER

All articles in the "Singapore - Tax Series" published on this website are original. Due to the assumptions made in the analysis, the conclusions are for reference only and do not take into account the potential impact of subsequent changes in Singapore's relevant tax laws, regulations, or practices. We are not responsible for any actions taken based on the information in this article, nor for any errors or omissions. We expressly disclaim any liability for anything done or not done by any person (whether reader or anyone else) in reliance on any part of this article.

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RECOMMENDED LINKAGES

◎ [Q] Summary of FAQs and Replies for Existing Company in Singapore

◎ [O-SG] Commonly used Singapore official website

◎ [SG] List of Fees – Secretary | Finance (Accounting & Report) | Tax | Others