§ 2A — Purpose of Act

2A.—(1) Income tax is charged in accordance with this Act on the income of a person accruing in or derived from Singapore or received in Singapore from outside Singapore, or on such amounts deemed to be chargeable as such income under this Act.(2) Income tax (namely, DTT and MTT) is also charged in accordance with the MMT Act on the income of a multinational enterprise group for the following purposes:(a)

to implement the Global Anti-Base Erosion Model Rules (Pillar 2) relating to the top-up tax under the income inclusion rule (IIR);

(b)

to implement a domestic top-up tax that is intended to be a qualified domestic minimum top-up tax (QDMTT) within the meaning of those Rules.

(3) The liabilities of a person to the taxes mentioned in subsections (1) and (2) are cumulative.

(4) Sections 2 (except for definitions of terms used in provisions applied under subsection (6) insofar as not modified by the MMT Act), 3A, 5, 7, Parts 3 to 15 (except section 57), sections 62 to 63, 66 to 71, Part 17, sections 81, 82, 84, 85, 86, 88, 91 to 92L, 93, 93AA, 93A, 93C, 94 to 101, 102A, 103, 104, 104A, Parts 20A, 20B and 21, and the Schedules do not apply in relation to DTT and MTT.[Act 25 of 2025 wef 08/12/2025]

(5) Subsection (4) does not affect the operation of —(a)

section 15(1)(g) (in relation to the disallowance of deductions for DTT and MTT); and

(b)

section 49 (in relation to arrangements for relief from double taxation for DTT, and any tax of a similar character imposed by the laws of another country).

(6) The provisions of this Act not disapplied by subsection (4) apply in relation to DTT and MTT, but only in accordance with the MMT Act.[Act 36 of 2024 wef 20/03/2025]

—(1) Income tax is charged in accordance with this Act on the income of a person accruing in or derived from Singapore or received in Singapore from outside Singapore, or on such amounts deemed to be chargeable as such income under this Act.

(2) Income tax (namely, DTT and MTT) is also charged in accordance with the MMT Act on the income of a multinational enterprise group for the following purposes:(a)

to implement the Global Anti-Base Erosion Model Rules (Pillar 2) relating to the top-up tax under the income inclusion rule (IIR);

(b)

to implement a domestic top-up tax that is intended to be a qualified domestic minimum top-up tax (QDMTT) within the meaning of those Rules.

(3) The liabilities of a person to the taxes mentioned in subsections (1) and (2) are cumulative.

(4) Sections 2 (except for definitions of terms used in provisions applied under subsection (6) insofar as not modified by the MMT Act), 3A, 5, 7, Parts 3 to 15 (except section 57), sections 62 to 63, 66 to 71, Part 17, sections 81, 82, 84, 85, 86, 88, 91 to 92L, 93, 93AA, 93A, 93C, 94 to 101, 102A, 103, 104, 104A, Parts 20A, 20B and 21, and the Schedules do not apply in relation to DTT and MTT.[Act 25 of 2025 wef 08/12/2025]

(5) Subsection (4) does not affect the operation of —(a)

section 15(1)(g) (in relation to the disallowance of deductions for DTT and MTT); and

(b)

section 49 (in relation to arrangements for relief from double taxation for DTT, and any tax of a similar character imposed by the laws of another country).

(6) The provisions of this Act not disapplied by subsection (4) apply in relation to DTT and MTT, but only in accordance with the MMT Act.[Act 36 of 2024 wef 20/03/2025]