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Taxes · PDF

Pillar 2 Module 1B: Singapore MTT and DTT Scope

This module identifies the group threshold, constituent entities and Singapore charging rules.

Source checked · 11 October 2026

Who falls within scope

Singapore applies MTT and DTT to financial years beginning on or after 1 January 2025. An MNE group must reach EUR750 million of consolidated revenue in at least two of the four immediately preceding years. The test uses the ultimate parent’s consolidated statements, not only Singapore revenue or a single entity’s turnover, and scales the threshold for a non-12-month year. Identify the group, entity locations and excluded entities before computing tax. A wholly domestic group is not an MNE group under the illustrated definition.

Distinct charging responsibilities

MTT implements the IIR for foreign entities through relevant Singapore parents. DTT addresses Singapore entities and specified Singapore-created stateless entities, generally through a designated paying entity. They apply in addition to ordinary corporate income tax under separate legislation. The slides distinguish transparent entities, reverse hybrids, minority-owned entities and joint ventures rather than applying one entity rule to all structures. Singapore’s UTPR was described as a matter for later consideration, not an implemented charge in this edition.

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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