Three coordinated rules
The presentation separates the Qualified Domestic Minimum Top-Up Tax, Income Inclusion Rule and Undertaxed Profits Rule. Their order is designed to avoid several jurisdictions collecting the same top-up tax. QDMTT first addresses low-taxed income in its own jurisdiction. IIR generally operates down a parent-entity chain, with domestic top-up tax deducted. UTPR is the backstop for an amount not fully collected under IIR, allocated using substance-related factors. The 15% minimum concerns the jurisdictional GloBE calculation, not a replacement of every country’s ordinary corporate rate.
Using this module
Part A introduces BEPS 2.0, the common-approach framework and the OECD model rules, commentary and administrative guidance through the January 2026 Side-by-Side package. It is the conceptual introduction; Part B addresses Singapore’s scope and charging provisions. Distinguish an OECD rule description from what Singapore has implemented. Read the second-edition amendment note alongside older recordings so that a previously recorded explanation is not assumed to reflect every subsequent update.
Official source
A concise, independent Apex Gateway guide based on the official English source, not a reproduction of the complete document. Consult the original for full conditions, exceptions and subsequent updates.
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