Implementation of GloBE rules and Domestic Minimum Top-up Tax in 2025

In Budget 2024, Singapore announced the implementation of the Income Inclusion Rule (“IIR”) and Domestic Minimum Top-up Tax (“DTT”) for businesses’ financial years starting on or after 1 January 2025. 

These measures will apply to Multinational Entity (“MNE”) Groups with annual revenues of at least EUR 750 million in the consolidated financial statements of the Ultimate Parent Entity (“UPE”) in at least two out of the four financial years immediately preceding the year of application. For instance, for the financial year 2025, the relevant financial years for the revenue threshold would be 2021 to 2024. The IRAS has issued guidelines on the application of the IIR and DTT, and businesses are encouraged to consult the OECD’s GloBE Model Rules, Commentary, and accompanying administrative guidance for further information and guidance. ​