Multinational Enterprise (Minimum Tax) Act 2024

• Act Code: MEMTA2024
• Version as at: 25 Mar 2026
• Enacted by: Parliament

Section 1 — Short title and commencement

(1) This Act is the Multinational Enterprise (Minimum Tax) Act 2024.(2) A provision of this Act does not come into operation except on a date and in the manner mentioned in subsection (3). (3) The Minister may, from time to time, by order i

Section 2 — Interpretation

(1) In this Act —“acceptable financial accounting standard” means —(a) the International Financial Reporting Standards (IFRS) published by the International Accounting Standards Board (IASB); (b) the generally accepted accounting principles

Section 3 — “Flow‑through entity”, “reverse hybrid entity” and meaning of fiscal transparency

(1) In this Act, an entity is a “flow‑through entity” to the extent it is fiscally transparent with respect to any of its income, expenditure, profit or loss —(a) if it is established, formed, incorporated or registered under the laws of Si

Section 4 — “Permanent establishment” and “main entity”

(1) In this Act, a “permanent establishment” is —(a) a place of business (including a deemed place of business under an applicable tax treaty in force) situated in a jurisdiction where it is treated as a permanent establishment in accordanc

Section 5 — Jurisdiction where entity or permanent establishment is located

(1) For the purposes of this Act, an entity (not being a flow‑through entity) is located in a jurisdiction if —(a) it is a tax resident of that jurisdiction based on its place of management, establishment, formation, incorporation, registra

Section 6 — Jurisdiction where entity is located: 2 or more jurisdictions

(1) This section applies where an entity (X) is located in 2 or more jurisdictions in a financial year under section 5(1).(2) If there is an applicable tax treaty in force between 2 of these jurisdictions, X is located in the jurisdiction t

Section 7 — Minimum rate

The minimum rate is 15%.

Section 8 — MNE group to which this Act applies

(1) This Act applies to an MNE group for a financial year beginning on or after 1 January 2025 if its consolidated group revenue (determined by reference to the consolidated financial statements of its ultimate parent entity) for at least 2

Section 9 — Currency

(1) Unless otherwise specified in subsection (3) or (4) or in the regulations, calculations under this Act in relation to an MNE group, or a constituent entity of the group, are to be carried out in the following currency (called in this se

Section 10 — Act to be construed as one with ITA

(1) This Act charges taxes on the income of MNE groups, known as the MTT and the DTT.(2) This Act is to be construed as one with the ITA. —(1) This Act charges taxes on the income of MNE groups, known as the MTT and the DTT. (2) This Act is

Section 11 — Purpose of this Part

(1) The purpose of this Part is to implement the GloBE rules relating to the top‑up tax under the income inclusion rule (IIR).(2) For that purpose, this Part makes provision for a tax payable in respect of a constituent entity located in a

Section 12 — Entity chargeable with MTT

An entity (called in this Act a chargeable entity) is chargeable with MTT for a financial year if —(a) the entity is a responsible member of an MNE group at any time in the financial year; (b) this Act applies to the MNE group for the finan

Section 13 — Responsible members of MNE group

(1) The ultimate parent entity of an MNE group is a responsible member of the MNE group if it is not an excluded entity and is —(a) located in Singapore; or (b) subject to a qualified IIR under the law of the jurisdiction where it is locate

Section 14 — Amount of MTT chargeable on chargeable entity

(1) Subject to subsection (2), the amount of MTT chargeable on a chargeable entity for a financial year is the sum of the top‑up tax (determined in accordance with sections 15, 24 and 25) of each relevant entity of the chargeable entity for

Section 15 — Top‑up tax for relevant entity other than investment entity or insurance investment entity

(1) In this Part, the top‑up tax for a relevant entity (other than an investment entity or an insurance investment entity) of a chargeable entity for a financial year is the top‑up amount of the relevant entity for the financial year multip

Section 16 — Top‑up amounts of constituent entities other than special entities

(1) In this Part, a constituent entity (not being a special entity) of an MNE group has a top‑up amount for a financial year if the amount determined under subsection (2) or (3) is a positive amount, and that positive amount is considered t

Section 17 — Effective tax rate for constituent entities other than special entities

(1) In this Part, the effective tax rate for the constituent entities (not being special entities) of an MNE group located in a jurisdiction for a financial year is determined by the formula where —(a) A is the sum of the adjusted covered t

Section 18 — Substance‑based income exclusion for constituent entities other than special entities

(1) For the purpose of section 16(6), the substance‑based income exclusion for the constituent entities (not being special entities) of an MNE group located in a jurisdiction for a financial year is determined by the formula A + B, where —(

Section 19 — De minimis exclusion

(1) This section applies in relation to the constituent entities (not being stateless entities, investment entities and insurance investment entities) of an MNE group located in a jurisdiction for a financial year (FY) if —(a) the average o

Section 20 — GloBE Safe Harbours

(1) This section applies if —(a) specified entities of an MNE group located in a jurisdiction are, in accordance with the regulations for applying a GloBE Safe Harbour, eligible for the GloBE Safe Harbour for a financial year; and (b) the f

Section 21 — Additional current top‑up amount for constituent entities other than special entities

(1) Where, for any financial year —(a) the sum of the GloBE income or loss (including any negative amount of GloBE income or loss) of all the constituent entities (not being special entities) of an MNE group located in a jurisdiction (calle

Section 22 — Top‑up amounts of stateless entities

(1) In this Part, the top‑up amount of a constituent entity that is a stateless entity is determined by applying sections 16, 17, 18 and 21 (and regulations made for the purposes of those sections) to the constituent entity as if it were th

Section 23 — Top‑up amounts of minority‑owned constituent entities and members of minority‑owned subgroup

(1) In this Part, the top‑up amount of a constituent entity that is a minority‑owned constituent entity (not being an investment entity or an insurance investment entity), and that is not a member of a minority‑owned subgroup, is determined

Section 24 — Top‑up tax for investment entities and insurance investment entities

(1) In this Part, the top‑up tax for a financial year for a relevant entity of a chargeable entity that is an investment entity or insurance investment entity, is the top‑up amount of the entity for the financial year.(2) In this Part, an i

Section 25 — Application of this Part to joint ventures and JV subsidiaries

(1) For the purposes of this Part, a standalone JV, or an entity of a JV group, that —(a) is connected to an MNE group; and (b) has a top‑up amount (as determined under this section), is treated as a relevant entity of the MNE group. (2) Wh

Section 26 — Multi‑parent groups

The Minister may make regulations under section 84 in accordance with the GloBE rules to prescribe how the provisions of this Act apply in relation to a multi‑parent group.[Act 25 of 2025 wef 01/01/2025]

Section 27 — Purpose of this Part

(1) The purpose of this Part is to implement a top‑up tax in respect of an MNE group that is intended to be a qualified domestic minimum top‑up tax within the meaning of the GloBE rules.[Act 25 of 2025 wef 01/01/2025] (2) For that purpose,

Section 28 — DTT payable in respect of MNE group and amount of DTT

(1) DTT is payable in respect of an MNE group for a financial year where —(a) the MNE group is one to which this Act applies for that financial year; (b) at least one of its constituent entities is located in Singapore or is a section 29(b)

Section 29 — Top‑up amount of MNE group

In this Part, the top‑up amount for an MNE group for a financial year is the sum of —(a) the top‑up amount of every constituent entity (not being a special entity) of the MNE group located in Singapore for the financial year; (b) the top‑up

Section 30 — Top‑up amounts of constituent entities

(1) This section applies for the purposes of determining under this Part the top‑up amounts of the entities in section 29.(2) Sections 16 to 21 apply to determine the top‑up amount of a constituent entity (not being a special entity) of the

Section 31 — Registration of MNE group

(1) An MNE group to which this Act applies for a financial year, and that has a constituent entity located in Singapore (including a joint venture or JV subsidiary located in Singapore and connected to the MNE group) or a section 29(b) enti

Section 32 — Registration of MNE group by Comptroller

(1) This section applies where there are reasonable grounds for believing that an MNE group is one that must be registered under this Part by virtue of section 31, but has yet to be registered.(2) The Comptroller may register the MNE group.

Section 33 — Designated local GIR filing entity

(1) A constituent entity located in Singapore of a registered MNE group that satisfies the conditions prescribed by the regulations, must be designated as the designated local GIR filing entity of the MNE group in accordance with subsection

Section 34 — Designated local DTT filing entity

(1) A constituent entity located in Singapore of a registered MNE group that satisfies the conditions prescribed by the regulations, must be designated as the designated local DTT filing entity of the MNE group in accordance with subsection

Section 35 — Ultimate parent entity of registered MNE group must inform Comptroller of certain events

The ultimate parent entity of a registered MNE group must inform the Comptroller, in the form and manner specified by the Comptroller and within the prescribed time, of the occurrence of any prescribed event relating to the MNE group, and a

Section 36 — Surcharge for failure to register

(1) This section applies where the ultimate parent entity of an MNE group to which this Act applies for a financial year, fails to register the MNE group in accordance with section 31.(2) The Comptroller may make an assessment of a surcharg

Section 37 — Record keeping

(1) Regulations may be made under section 84 to require prescribed entities to keep and retain in safe custody records that satisfy the requirement in subsection (2), for a period specified in the regulations, and for this purpose different

Section 38 — Cancellation or suspension of registration

(1) Where the ultimate parent entity of a registered MNE group (being one registered on the basis that it was an MNE group to which this Act applies for an earlier financial year) satisfies the Comptroller that the MNE group is not one to w

Section 39 — Returns deemed furnished by due authority

(1) A return, statement or form purporting to be furnished under this Act by or on behalf of any entity is for all purposes deemed to have been furnished by that entity unless the contrary is proved.(2) Any person signing any such return, s

Section 40 — GloBE information return

(1) Subject to subsection (2), the designated local GIR filing entity of a registered MNE group to which this Act applies for a financial year must file by the due date with the Comptroller, in the form and manner determined by the Comptrol

Section 41 — Returns of MTT

(1) Every responsible member of a registered MNE group located in Singapore to which this Act applies for a financial year must, by the due date, furnish to the Comptroller in the form and manner determined by the Comptroller, either —(a) i

Section 42 — Payment of MTT

(1) A responsible member that has furnished a return under section 41(1) for a financial year must, no later than one month after the due date in that provision, pay to the Comptroller, without demand and in the manner determined by the Com

Section 43 — Returns of DTT

(1) The designated local DTT filing entity of a registered MNE group to which this Act applies for a financial year must, by the due date, furnish to the Comptroller in the form and manner determined by the Comptroller, either —(a) if there

Section 44 — Payment of DTT

(1) A designated local DTT filing entity that has furnished a return under section 43 for a financial year must, no later than one month after the due date, pay to the Comptroller, without demand and in the manner determined by the Comptrol

Section 45 — Election to pay amount attributable to an entity separately

(1) An MNE group may, through its designated local DTT filing entity, elect for the part of its top‑up amount (called in this section amount Y) for a financial year that is attributable to a constituent entity of the MNE group or a joint ve

Section 46 — Power of Comptroller to obtain information

(1) Sections 64 to 65E (except section 65B(1E)) of the ITA have effect for the purpose of enabling the Comptroller to obtain any information or evidence for the purpose of the administration or enforcement of this Act.(2) The sections menti

Section 47 — Powers of arrest and disposal of items furnished or seized

Sections 65F to 65K of the ITA apply with the following modifications:(a) a reference to a provision that is incorporated by reference in this Act is to that provision as applied and modified by this Act; (b) a reference to an offence under

Section 48 — Information may be used for administration of Act

Despite any obligation as to secrecy imposed under any written law or rule of law, the Comptroller of Goods and Services Tax, the Comptroller of Property Tax, the Chief Assessor or the Commissioner of Stamp Duties may transmit information o

Section 49 — Assessment

(1) This section applies where —(a) a return required to be furnished under section 41 or 43 has not been furnished by the due date mentioned in that section; or (b) it appears to the Comptroller that a return is incomplete, incorrect or no

Section 50 — Assessment in event of failure to register

(1) This section applies —(a) where the ultimate parent entity of an MNE group to which this Act applies for a financial year, fails to register the MNE group in accordance with section 31; or (b) after the registration of the MNE group und

Section 51 — Assessment in event of fraud

(1) Despite section 49, where, in the Comptroller’s opinion, any form of fraud or wilful default has been committed by or on behalf of any person in connection with or in relation to any liability for MTT or DTT, the Comptroller may, for th

Section 52 — Errors and defects in assessment and notice

(1) No assessment or other proceeding purporting to be made in accordance with the provisions of this Act is to be quashed, or is deemed to be void or voidable, for want of form, or is affected by reason of a mistake, defect or omission the

Section 53 — Objections

(1) If a chargeable entity disputes an assessment of MTT or DTT payable by it for a financial year, the chargeable entity may (whether by itself or another entity authorised by it) apply to the Comptroller, by a written notice of objection,

Section 54 — Appeals to Board of Review

(1) The Board of Review established under Part 18 of the ITA (called in this Part the Board) may hear appeals against an assessment made by the Comptroller under this Act.(2) A chargeable entity that is aggrieved by such assessment, and tha

Section 55 — Appeals to General Division of High Court

(1) The appellant or the Comptroller may appeal to the General Division of the High Court from a decision of the Board on a question of law or of mixed law and fact.(2) The procedure governing and the costs of any such appeal to the General

Section 56 — Cases stated for General Division of High Court

(1) The Board may at any time and in regard to any appeal, with or without proceeding to the determination of the appeal, state a case on a question of law for the opinion of the General Division of the High Court.(2) A stated case must set

Section 57 — Assessments are final and conclusive

(1) Except as expressly provided in this Act, where no valid notice of appeal has been lodged within the time limited by this Part (including other written law as applied by this Part) against an assessment, or where an assessment has been

Section 58 — Recovery of unpaid MTT, interest and penalty

(1) This section applies to —(a) an amount of MTT payable under section 42(1) or pursuant to an assessment, that has not been paid by the date it becomes due (called in this section the MTT in arrears); and (b) an amount of interest imposed

Section 59 — Recovery of unpaid DTT, interest and penalty

(1) This section applies to —(a) an amount of DTT payable under section 44(1) or (2) or pursuant to an assessment, that has not been paid on the date it becomes due (called in this section DTT in arrears); and (b) an amount of interest impo

Section 60 — Repayment of MTT and DTT

(1) If it is proved to the Comptroller’s satisfaction that any part of any MTT or DTT has been paid in excess of the amount payable under this Act, the payer is entitled to have the amount so paid in excess refunded.(2) A claim for repaymen

Section 61 — Right of contribution

(1) A liable entity (X) of or connected to an MNE group that has made payment to the Comptroller of any part of the DTT payable in respect of the MNE group for a financial year, has a right of contribution or indemnity from another liable e

Section 62 — Relief against double-counting

(1) Where a joint venture or JV subsidiary (X) connected to an MNE group is also a joint venture or JV subsidiary connected to another MNE group and DTT is payable in respect of both MNE groups for a financial year, the designated local DTT

Section 63 — Relief in respect of error or mistake

(1) If a chargeable entity alleges that any payment of MTT or DTT is excessive by reason of some error or mistake in a return made under this Act, it may, at any time not later than —(a) in the case of MTT — 31 December of the 5th year afte

Section 64 — Failure to make return

(1) Any person who fails or neglects without reasonable excuse to comply with section 41(1) or 43(1) shall be guilty of an offence and shall be liable on conviction to —(a) a fine not exceeding $5,000 and in default of payment to imprisonme

Section 65 — Failure to keep proper records

Any person who fails or neglects without reasonable excuse to comply with any regulations under section 37(1) shall be guilty of an offence and shall be liable on conviction to a fine not exceeding $5,000 and in default of payment to impris

Section 66 — Failure to file GloBE information return and notice

Any person who fails or neglects without reasonable excuse to comply with section 40(1) or (3) shall be guilty of an offence and shall be liable on conviction to —(a) a fine not exceeding $5,000 and in default of payment to imprisonment for

Section 67 — Penalty for information in GloBE information return or notice known to be false or misleading

Any person who, in purported compliance with section 40(1) or (3), produces to the Comptroller any document which contains any information, or provides to the Comptroller any information, known to the person to be false or misleading in a m

Section 68 — Penalty for incorrect return, etc.

(1) Any person that —(a) makes an incorrect return under section 41 or 43 by omitting, overstating or understating anything required to be included in the return for the purpose of reporting the amount of any MTT or DTT; or (b) gives to the

Section 69 — Serious fraudulent tax evasion

(1) Any person who wilfully with intent to evade or to assist any other person to evade payment of MTT or DTT —(a) prepares or maintains or authorises the preparation or maintenance of any false books of account or other records or falsifie

Section 70 — Offences by authorised and unauthorised persons

Any person who —(a) being a person appointed for the due administration of this Act or any assistant employed in connection with the assessment and collection of MTT or DTT —(i) demands from any person an amount in excess of the assessment

Section 71 — Offence for obstructing Comptroller or officers

Any person who obstructs or hinders the Comptroller or any officer in the discharge of his or her duties or the exercise of his or her powers under this Act shall be guilty of an offence and shall be liable on conviction to a fine not excee

Section 72 — MTT or DTT payable despite any proceedings

The institution of proceedings for, or the imposition of, a penalty, fine or term of imprisonment under this Act does not relieve any person from liability to payment of any MTT or DTT for which the person is or may be liable.

Section 73 — Consent for prosecution

(1) No prosecution may be commenced in respect of an offence under section 64, 65, 66, 67, 68 or 69 except at the instance or with the consent of the Comptroller or the Public Prosecutor.(2) No prosecution may be commenced in respect of an

Section 74 — Application of ITA provisions on offences

Sections 102 and 105 of the ITA apply to offences under this Part as they apply to offences under the ITA.

Section 75 — Composition of offences

(1) The Comptroller may compound any offence under sections 64, 65, 66, 67, 68, 69 and 71.(2) The Comptroller may authorise either generally or specifically an officer to compound any offence under sections 64, 65, 66, 67, 68, 69 and 71.

Section 76 — Authorisation of officers

Without limiting section 4(5) of the ITA, the Comptroller may authorise a person authorised under section 4(1) of the ITA to investigate offences under this Act, and to exercise any power in sections 65B(1A), (1B), (1C) or (1D), 65F, 65G, 6

Section 77 — Liability of managers of entities

The manager or principal officer in Singapore of every entity is answerable for doing all such acts, matters and things as are required to be done by the entity under this Act.

Section 78 — Duty of liquidator, etc., on winding up of entity

(1) Where an entity is being wound up or dissolved, the liquidator or receiver of the entity, or any other person overseeing the winding up or dissolution of the entity, is answerable for doing all such acts, matters and things as are requi

Section 79 — Provisions relating to interest and penalty

(1) Any interest or penalty imposed under this Act is not part of the tax paid for the purposes of claiming relief under any of the provisions of this Act.(2) Any penalty imposed under section 87(1) of the ITA (as applied by this Act) is co

Section 80 — Saving for criminal proceedings

The provisions of this Act do not affect any criminal proceedings under any other written law.

Section 81 — Admissibility of certain statements and documents as evidence

(1) Statements made or documents produced by or on behalf of any person are not inadmissible in evidence against the person in any proceedings to which this section applies by reason only that the person was or may have been induced to make

Section 82 — Protection of informers

(1) Except as provided in subsection (3), no witness in any civil or criminal proceedings is obliged or permitted —(a) to disclose the identity of an informer who has given any information (whether the information is given before, on or aft

Section 83 — Application of other ITA provisions

(1) This section applies other ITA provisions for the purposes of this Act.Official secrecy (2) Section 6 of the ITA applies with the following modifications:(a) a reference in that section to any document, information, return, or assessmen

Section 84 — Regulations

(1) The Minister may make regulations —(a) to provide for adjustments, including any allocation to or from another entity, to be made to the FANIL or the GloBE income or loss of entities (including adjustments to be made to the revenue of e

Section 85 — Related amendments to Income Tax Act 1947

In the Income Tax Act 1947 —(a) in section 2(1), after the definition of “crops”, insert —“ “DTT” means the domestic top‑up tax imposed under the MMT Act;”; (b) in section 2(1), after the definition of “employee”, insert —“ “excluded top‑up

Section 86 — Related amendments to Inland Revenue Authority of Singapore Act 1992

In the Inland Revenue Authority of Singapore Act 1992 —(a) in the Third Schedule, after item 10, insert —“11. Multinational Enterprise (Minimum Tax) Act 2024.”; and (b) in the Fourth Schedule, in item 1, replace “and Part 9 of the Casino Co