Since the Organisation for Economic Co-operation and Development (OECD) introduced its Base Erosion and Profit Shifting (BEPS) 2.0 Pillar Two framework, multinational enterprise (MNE) groups around the world have been preparing for a new global minimum tax regime.
The rules are aimed at ensuring that large MNE groups are subject to a minimum effective tax rate of 15% in each jurisdiction where they operate.
In Singapore, these rules have been implemented through the Multinational Enterprise (Minimum Tax) Act (MMT Act) 2024, which introduced the Multinational Enterprise Top-up Tax (MTT) and Domestic Top-up Tax (DTT) for in-scope groups. The regime also includes a Pillar Two registration requirement for affected MNE groups.
The first registration deadline falls on 30 June 2026 for MNE groups whose first in-scope financial year ends on 31 December 2025. For groups with later financial year ends, registration is generally required within six months after the end of their first financial year to which the MMT Act applies.
In this article, we explain:
- Which MNE groups should register for Pillar Two in Singapore?
- Pillar Two registration deadlines in Singapore
- What information is required for Pillar Two registration?
- Understanding the GloBE Information Return (GIR)
- How Hawksford can help
- What are the filing obligations after Pillar Two registration?
- Frequently asked questions
Which MNE groups should register for Pillar Two in Singapore?
Registration for Pillar Two in Singapore is generally required if your MNE group meets the EUR750 million revenue threshold and has a relevant presence in Singapore.
The revenue threshold is assessed based on the consolidated financial statements of the Ultimate Parent Entity (UPE). However, take note that the assessment is not limited to the current financial year.
Under the two-out-of-four-year revenue test, your group will typically be within scope if it recorded consolidated revenue of at least EUR750 million in at least two of the four financial years immediately preceding the tested financial year. As such, it is important to review your group's revenue position over the entire four-year period rather than focusing solely on its most recent results.
In addition to meeting the revenue threshold, your group must also have a relevant presence in Singapore. This generally means having at least one Singapore Constituent Entity (CE), Joint Venture (JV) or Reverse Hybrid Entity (RHE) within the group structure.
Where both conditions are met, your group will generally need to register under the MMT Act.
Pillar Two registration deadlines in Singapore
If your group falls within the scope of Singapore's Pillar Two regime, you must register within six months after the end of the first financial year to which the MMT Act applies.
For example, if your group's first in-scope financial year ends on 31 December 2025, registration must be completed by 30 June 2026. The applicable registration deadline will depend on your financial year-end:
| Financial year-end | Pillar Two registration deadline |
|---|---|
| 31 December 2025 | 30 June 2026 |
| 31 March 2026 | 30 September 2026 |
| 30 June 2026 | 31 December 2026 |
The registration process establishes your group's obligations relating to the MTT, DTT and GloBE Information Return (GIR) filing requirements under Singapore's Pillar Two framework. Importantly, registration may be required even if no MTT or DTT is expected to be payable.
Registration is a one-time process. Once your group has successfully registered, there is ordinarily no requirement to submit a new registration each year, although ongoing compliance, filing obligations and updates to registration information may continue to apply. If you need help meeting your Pillar Two registration deadline, please get in touch with our team for support.
Risks of late Pillar Two registration
Late Pillar Two registration may expose your group to compliance, administrative risks and statutory consequences. As mentioned, registration establishes a group's obligations under the regime. Delays may therefore also reduce the time available to prepare for subsequent GIR, DTT and MTT filing requirements, and may result in surcharge or penalty exposure where applicable under the MMT Act.
What information is required for Pillar Two registration?
Having determined that your MNE group is required to register, the next step is to gather the information needed for the registration process. Much of this information relates to the MNE group, the UPE, Singapore entities, designated filing entities and reporting arrangements.
Information required for Pillar Two registration may include:
- MNE group name and first financial year under the MMT Act
- UPE name, Tax Identification Number (TIN) and jurisdiction
- Whether the deemed consolidation test applies
- Details of Singapore in-scope entities
- Details of excluded entities located in Singapore
- Details of Singapore-incorporated or registered entities that changed tax residency after 30 November 2021
- Identification of the Designated Local GIR Filing Entity (GFE)
- Identification of the Designated Local DTT Filing Entity (DFE)
- Contact details of the individuals responsible for Pillar Two compliance and reporting
Understanding the GloBE Information Return (GIR)
The GIR is the principal reporting document under the OECD's Pillar Two framework and a key component of ongoing compliance for in-scope MNE groups. It is used to provide tax authorities with the information needed to assess whether the Global Anti-Base Erosion (GloBE) Rules have been correctly applied and whether any top-up tax may be payable.
As the cornerstone compliance document under the regime, the GIR brings together information from across the MNE group and provides a standardised framework for reporting Pillar Two calculations. This may include information relating to the group's structure, jurisdictional effective tax rate (ETR) calculations and any top-up tax computations required under the GloBE Rules.
The GIR may also contain details of elections made by the group, including the application of available safe harbour provisions where the relevant conditions are satisfied.
How to designate the Singapore GIR filing entity (GFE)
For registration purposes, an MNE group must generally designate a single CE to serve as both the DFE and the GFE. This entity will be responsible for fulfilling the relevant Singapore DTT and GIR obligations.
When designating a GFE, businesses should consider which CE is best placed to manage the reporting process. Factors such as access to relevant information, reporting capabilities and the entity's role within the wider group structure may all be relevant. Selecting an appropriate GFE can help support accurate and timely DTT and GIR filings.
How Hawksford can help
As registration must be completed within the prescribed timeframe, it is often beneficial to begin gathering the required information as early as possible. Our team can assist with assessing whether an MNE group falls within the scope of Singapore's Pillar Two regime and identifying the obligations that may apply.
This includes reviewing group structures, identifying the appropriate filing entities, including the GFE, and coordinating the details needed for registration and ongoing compliance. After registration, we can also help you prepare for the reporting obligations that follow. Please get in touch with us to discuss further.
What are the filing obligations after Pillar Two registration?
After completing Pillar Two registration in Singapore, your group may have ongoing filing obligations relating to the GIR, DTT returns and, where applicable, MTT returns.
One of the key obligations may be the annual filing of the GIR. The GIR is used to report information relating to your group’s structure, jurisdictional effective tax rate (ETR) calculations, top-up tax computations and any relevant elections made under the GloBE Rules. As the principal reporting document under the Pillar Two framework, the GIR plays a central role in demonstrating compliance with the regime.
Separate DTT returns and, where applicable, MTT returns may also be required. These filings are distinct from the GIR and may require additional information to support the calculation and reporting of any top-up tax liabilities arising in Singapore.
These filings are administered through IRAS' digital services. Businesses should therefore ensure that the appropriate filing entities, reporting processes and governance procedures are in place to support timely and accurate submissions.
Frequently asked questions
When does Pillar Two registration start in Singapore?
Pillar Two registration became available in Singapore in May 2026. If your group is subject to the Multinational Enterprise (Minimum Tax) Act (MMT Act) 2024, registration must be submitted within six months after the end of the first financial year to which the Act applies. For example, where your group's first in-scope financial year ends on 31 December 2025, registration must be submitted by 30 June 2026.
What are the common challenges during Pillar Two registration?
The most common Pillar Two registration challenges include identifying relevant Singapore entities, gathering Tax Identification Numbers (TINs), designating the appropriate filing entities and coordinating information across multiple jurisdictions.
For larger MNE groups, obtaining and validating information from different business units and stakeholders can be particularly time-consuming, especially where Pillar Two compliance processes are still being established. Early planning can help reduce administrative complexity and support timely registration. If your group is facing challenges in gathering information, identifying filing entities or coordinating registration across multiple jurisdictions, please get in touch with us.
Should MNE groups prepare for Pillar Two registration before the filing window opens?
Yes, MNE groups should begin preparing for Pillar Two registration before the filing window opens, particularly where information must be collected from multiple entities or jurisdictions. Early preparation can help ensure that the necessary information is available when registration becomes due and reduce the risk of delays.
Can a non-Singapore parent entity complete the Pillar Two registration?
Yes, an overseas Ultimate Parent Entity (UPE) may submit the Pillar Two registration on behalf of the MNE group, even if it does not have a Singapore Tax Identification Number (TIN). Alternatively, the UPE may authorise a representative to make the submission on the group's behalf.
What risks arise from incorrect entity designation during registration?
Incorrectly identifying a filing entity or reporting contact can create practical challenges later in the compliance process. This may lead to delays in meeting filing requirements, difficulties in managing reporting responsibilities or the need to amend information that has already been submitted. As designated filing entity plays an important role in relation to GIR and DTT requirements, it is advisable to review the appointment carefully before proceeding with registration.
What happens if group structure changes after registration?
Changes to your group's structure after registration do not automatically require a new registration to be submitted. However, acquisitions, disposals, mergers, internal reorganisations or the creation of new Singapore entities may affect your group's ongoing Pillar Two obligations. Businesses should therefore consider whether any changes affect their ongoing Pillar Two compliance obligations and ensure that subsequent filings accurately reflect the group's current structure.
How are multiple Singapore entities handled during Pillar Two registration?
Where your MNE group has multiple entities in Singapore, information relating to each relevant entity must be included as part of the registration process. This may include Constituent Entities (CEs), Joint Ventures, Joint Venture subsidiaries, Reverse Hybrid Entities and certain other entities within the group. Businesses should therefore ensure that the required entity information is identified and reviewed before registration is submitted.
Do excluded entities affect Pillar Two registration requirements?
Yes. Although excluded entities may not be subject to all aspects of the Pillar Two rules, information relating to excluded entities may still be required during the registration process. IRAS requires MNE groups to provide information on excluded entities incorporated, registered or located in Singapore as part of the registration requirements. Businesses should therefore ensure that excluded entities are identified and reviewed when preparing their registration submission.
Can Pillar Two registration deadlines be extended?
Extension requests are generally limited. IRAS has indicated that MNE groups with a financial year of less than 12 months that begins and ends in 2025 may apply for an extension of time to register if they are unable to meet the prescribed deadline. Such requests are considered on a case-by-case basis. Outside of these circumstances, businesses should not assume that an extension will be available.
Should MNE groups appoint a local corporate service provider (CSP) for Pillar Two registration?
Whether to appoint a local CSP depends on your group's resources, structure and familiarity with Singapore's Pillar Two requirements. For groups with complex structures or limited local resources, engaging a CSP or tax adviser may help coordinate the registration process and support ongoing compliance. If you need support with Pillar Two registration in Singapore, please get in touch with us.
How does Singapore registration fit into a broader Pillar Two compliance strategy?
For many in-scope MNE groups, Singapore Pillar Two registration is the first formal compliance requirement under the regime and forms part of the broader process of meeting MTT, DTT and GIR obligations. While registration is a one-time process, it establishes your group's obligations under the MMT Act 2024.
Registration should therefore be viewed as one component of a wider compliance framework that may include data collection, effective tax rate calculations, top-up tax assessments, GIR reporting and ongoing governance processes across multiple jurisdictions.
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