Multinational Enterprise (Minimum Tax) Act 2024 in operation on 1 January 2025
23 January 2025
Pursuant to section 1(3) of the Multinational Enterprise (Minimum Tax) Act 2024 (“Act”), the Minister for Finance may, from time to time, by order in the Gazette, declare that the Act or any provision thereof comes into operation on a date specified in the order, and the Act or that provision (as the case may be) comes into operation on that date and remains in force until the order is revoked by the Minister.
On 30 December 2024, the Multinational Enterprise (Minimum Tax) Act 2024 (Declaration under Section 1(3)) Order 2024 was gazetted, pursuant to which:
- the Act came into operation on 1 January 2025; and
- the first financial year of a large multinational enterprise (“MNE”) group in relation to which the Act has effect is the first financial year of the MNE group that begins on or after 1 January 2025.
The Act implements two new top-up taxes under the Base Erosion and Profit Shifting 2.0 initiative (“BEPS 2.0”):
- Domestic Top-up Tax (“DTT”); and
- Multinational Enterprise Top-up Tax (“MTT”). The MTT applies the Income Inclusion Rule, which is part of the BEPS 2.0 Global Anti-Base Erosion (“GloBE”) rules.
The implementation of the DTT and MTT ensures that Singapore is aligned with the international implementation of BEPS 2.0.
To support the implementation of the Act, the Multinational Enterprise (Minimum Tax) Regulations 2024 were also gazetted on 30 December 2024 and came into operation on 1 January 2025.
For more information about the Act, please read our article “Multinational Enterprise (Minimum Tax) Bill passed to implement two new top-up taxes under BEPS 2.0”.
Reference materials
The following materials are available from Singapore Statutes Online sso.agc.gov.sg: