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Taxes · PDF

Pillar 2 Module 5: Transition Years and Opening Deferred Taxes

The June 2026 module explains the tax attributes carried into a jurisdiction’s GloBE transition year.

Source checked · 11 October 2026

Identifying the transition year

The computation transition year is determined for each jurisdiction, considering when relevant IIR, UTPR or Singapore DTT rules first apply and when transitional safe-harbour protection ceases. The slides show that a Singapore jurisdiction can have an earlier transition year because a foreign IIR already applied. Conversely, safe-harbour treatment may defer the computation transition year. This jurisdictional test should not be substituted for the separate group-level transition-year definition used to extend filing deadlines.

Opening balances and a DTT reset

Opening deferred-tax assets and liabilities are brought in under the specified transition rules, generally using the lower of the domestic rate and 15%. Recognition and valuation adjustments are disregarded, while qualifying loss assets can have a different recast where the required GloBE-loss evidence exists. The module also addresses exclusions for certain pre-regime arrangements and a new DTT transition-year reset. Its reset rules affect old liabilities, negative-tax carry-forwards and loss-related attributes; retaining an ordinary accounting opening balance without these checks can distort later top-up calculations.

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.

Read the official PDF ↗
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