Singapore: Registration for Multinational Enterprises Top-up Tax (MTT) and Domestic Top-up Tax (DTT)

Mandatory registration for MTT, DTT and GloBE Information Return

Under the MMT Act, all in-scope MNE groups are required to register for MTT, DTT and the filing of the GloBE Information Return (GIR).

The online registration process is now available.

Below please find some information designated to help MNE groups prepare for registration:

Registration Requirement

An MNE Group is required to be registered if it:

• Has revenue of EUR 750 million or more; and
• Has at least one Constituent Entity (CE) or Joint Venture located in Singapore, or a Reverse Hybrid Entity incorporated or registered in Singapore

Where the MNE Group is required to be registered:

• The UPE of the MNE Group must notify the Comptroller of Income Tax by submitting the group’s information through an online registration form.
• 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 calendar year end MNE Groups, the registration should be done by 30 June 2026.
• For MNE Groups with a financial year of less than 12 months that begins and ends in 2025 and is unable to submit the registration form within 6 months after its financial year end are required to email IRAS at IRAS_PillarTwo_Compliance@iras.gov.sg with the subject header “Request for Extension for Registration under the MMT Act”.
• If the UPE wishes to appoint a representative to register the MNE Group on its behalf, the representative may be either from a CE of the MNE Group located in Singapore or a local tax agent.
• The representative appointed by the UPE must submit the registration form together with a Letter of Authorization. This letter, issued on the UPE’s company letterhead, must explicitly state that the representative’s organization is authorized to submit the registration form and to act on behalf of both the UPE and MNE Group in all registration related matters.

The information required to complete the registration form is largely in line with the expectations under the GloBE model rules and prior IRAS guidance.

The registration form includes the following sections:

• Part I – General information on the UPE and the MNE Group
• Part II – MTT-related information (details of responsible members of the MNE Group)
• Part III – DTT-related information (including identification of the designated GIR and DTT filing entity and in-scope entities)
• Part IV – Tax residency changes after 30 November 2021
• Part V – Declaration

What Happens After Registering?

The registration should be processed within one month from IRAS receiving complete information. Processing time may be delayed if information is incomplete.
Once registered, the MNE Group will be assigned a Group Identification Number (Group ID).

The filing of the DTT return and the GIR will be done via digital services in myTaxPortal using the Group ID.

For MTT purposed, the filing of the MTT return will be done via digital services in myTaxPortal using the UEN of the Responsible Member (RM).

The RM is not required to submit any application to appoint the CorpPass Administrator (CPA) as it would already have a CPA under its UEN. The CPA of the RM can authorize its personnel or a tax agent to handle the tax matters for MTT in myTaxPortal using its UEN from 1 January 2027.

Penalties and Compliance

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